COMMISSION STAFF WORKING DOCUMENT EVALUATION of the Directive 2006/126/EC of the European Parliament and of the Council of 20 December 2006 on driving licences
Date: 2022-01-21
Institutions: Directorate-General for Mobility and Transport, European Commission
Subjects: European driving licence, European standard, administrative cooperation, driving instruction, exchange of information, road safety, road transport, technical standard

EN 

  EN 

   EUROPEAN COMMISSION  Brussels, 21.1.2022  SWD(2022) 17 final  COMMISSION STAFF WORKING DOCUMENT  EVALUATION  of the Directive 2006/126/EC of the European Parliament and of the Council of 20 December 2006 on driving licences          {SWD(2022) 18 final}  
 
 
Table of contents 

1. 

INTRODUCTION ............................................................................................................................... 4 

1.1 

PURPOSE AND SCOPE OF THIS EVALUATION .............................................................................................. 4 

2. 

BACKGROUND TO THE INTERVENTION ............................................................................................ 6 

2.1 
2.2 

DESCRIPTION OF THE INITIATIVE AND ITS OBJECTIVES ................................................................................. 7 
BASELINE AND POINTS OF COMPARISON .................................................................................................. 8 

3. 

IMPLEMENTATION/STATE OF PLAY ............................................................................................... 12 

THE MAIN NOVELTIES INTRODUCED BY THE DIRECTIVE .............................................................................. 12 
INFRINGEMENTS RELATED TO THE IMPLEMENTATION OF DIRECTIVE 2006/126/EC ...................................... 13 
INFRINGEMENTS RELATED TO THE NON-COMMUNICATION OF THE TRANSPOSITION OF DIRECTIVE 2006/126/EC 

3.1 
3.2 
3.3 
AND ITS AMENDING ACTS. ............................................................................................................................... 14 
JUDGMENTS OF THE COURT OF JUSTICE OF THE EUROPEAN UNION ............................................................ 14 
3.4 

4.  METHOD ........................................................................................................................................ 16 

4.1 
4.2 

METHODOLOGY AND SOURCES OF INFORMATION ................................................................................... 16 
LIMITATIONS AND ROBUSTNESS OF FINDINGS ......................................................................................... 17 

5.  ANALYSIS AND ANSWERS TO THE EVALUATION QUESTIONS ......................................................... 21 

5.1 

EFFECTIVENESS ................................................................................................................................ 21 
5.1.1  General objectives ................................................................................................................... 21 
Enhancing road safety .................................................................................................................. 21 
Facilitating free movement for EU citizens ................................................................................... 23 
The specific objectives ............................................................................................................. 25 
Objective “Reducing administrative burden for drivers, administrations and enforcement 

5.1.1.1 
5.1.1.2 

5.1.2 

5.1.2.1 
authorities” 25 
5.1.2.2 
5.1.2.3 
5.1.2.4 
5.1.2.5  
5.1.2.6 
5.1.2.7 

5.2 
5.3. 
5.4 

5.5 

Objective “Establish uniform driving licence rules and requirements” ........................................ 27 
Objective “Reducing the possibilities of driving licence fraud and driving licence tourism” ........ 36 
Objective “Raising the driving skills of non-professional and professional drivers” ..................... 38 
Objective “Facilitate implementation and enforcement of driving licence rules” ........................ 41 
Objective “Protect novice drivers” ............................................................................................... 45 
Factors that contributed to or hindered the achievement of objectives ...................................... 47 
EFFICIENCY ...................................................................................................................................... 51 
RELEVANCE ..................................................................................................................................... 58 
COHERENCE .................................................................................................................................... 63 
Internal coherence of the provisions of the directive .............................................................. 63 
5.4.1 
External coherence of the directive with other legislation ...................................................... 64 
5.4.2 
5.4.3  Coherence with international legislation ................................................................................ 64 
5.4.4  Coherence with other EU legislation in the area of road safety and transport ...................... 65 
5.4.5  Coherence with vehicle type-approval legislation, the Digital Single Market and e-
Government initiatives in relation to digitalisation ............................................................................. 68 
Impacts of observed inconsistencies / gaps / overlaps ........................................................... 69 
5.4.6 
EU ADDED VALUE ............................................................................................................................ 71 

5.5.1  Benefits of intervening at EU level compared to acting at regional, national or international 
 ................................................................................................................................................ 71 
level 
5.5.2  Added value created by the directive and results that could have been achieved without it . 72 
Would it have been possible to have the same results without the directive? ................... 74 
5.5.3  

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6. 

CONCLUSIONS ............................................................................................................................... 77 

 

ANNEXES ....................................................................................................................................... 82 

ANNEX 1: PROCEDURAL INFORMATION .............................................................................................................. 83 
ANNEX 2: STAKEHOLDER CONSULTATION ........................................................................................................... 84 
ANNEX 3: METHODOLOGY .............................................................................................................................. 97 
ANNEX 4: INTERVENTION LOGIC ..................................................................................................................... 155 
ANNEX 5: TABLES AND GRAPHICS ................................................................................................................... 156 
ANNEX 6: REFIT COSTS AND BENEFITS ............................................................................................................ 170 

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Glossary 

Term or acronym 

Meaning or definition 

ACEM 

BVF 

CIECA 

EFA 

EEA 

EReg 

ETF 

ETSC 

FEMA 

FIA 

FIM 

Association des Constructeurs Européens de Motocycles 
(European Association of Motorcycle Manufacturers) 

Bundesvereinigung der Fahrlehrerverbände e.V. 
(Federal association of driving instructors’ associations (in Germany))  

Commission Internationale des Examens de Conduite Automobile  
(International Commission for Driver Testing) 

Europäische Fahrlehrer-Assoziation  
(European Driving School Association) 

European Economic Area (Iceland, Liechtenstein and Norway) 

Association of European Vehicle and Driver Registration Authorities 

European Transport Workers’ Federation 

European Transport Safety Council 

Federation of European Motorcyclists' Associations 

Fédération Internationale de l'Automobile 
(International Automobile Federation) 

Fédération Internationale de Motocyclisme 
(International Motorcycling Federation) 

GDLD 

Get Driving Licence Details (in RESPER) 

IFMC 

IRU 

OECD 

PTW 

International Federation Motorhome Clubs 

International Road Transport Union 

Organisation for Economic Co-operation and Development 

powered two wheeler 

RESPER 

Réseau permis de conduire (EU driving licence network) 

STR 

SWOV 

UETR 

Sveriges Trafikutbildares Riksförbund  
(Swedish National Association of Driver Educators) 

Stichting Wetenschappelijk Onderzoek Verkeersveiligheid 
((Dutch) Institute for Road Safety Research) 

Union Européenne des Transporteurs Routiers 
(European Road Haulers Association) 

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1.  INTRODUCTION 

This  report  presents  the  findings  of  the  ex-post  evaluation  of  Directive  2006/126/EC  of  the 
European Parliament and of the Council of 20 December 2006 on driving licences. 

The EU rules on driving licences were progressively set up through three  directives. The first 
directive1  was  introduced in  December 1980, followed by the second  directive2 of July 1991. 
Directive  2006/126/EC  on driving licences3, also  known as the third  driving  licence  directive 
(hereafter ‘the directive’), was adopted in December 2006. It has meanwhile been amended ten 
times, mainly to take into account scientific and technical progress. 

The directive was gradually applicable over time with some provisions being applicable as per 
19 January 20094, while the key provisions were only applicable after full transposition as per 
19 January 20135. 

The directive aims at harmonising the rules on driving licences in order to improve road safety, 
to facilitate the freedom of movement for citizens moving inside the Union, and to reduce the 
possibility of fraud.  

1.1 Purpose and scope of this evaluation 

As  more  than  12  years  have  passed  since  Member  States  started  applying  the  provisions 
contained in the directive, it was considered timely to assess how well it has performed relative 
to original expectations. The purpose of the evaluation is an assessment of the performance of 
all substantive provisions (Articles 1 to 15) of the directive across the European Union.  

The evaluation period spans from 2006, when the current directive was adopted, until 2018. 

Geographical scope - The evaluation covers the full geographical scope of the directive and 
assesses its effects in all Member States and the United Kingdom. 

Furthermore,  national  authorities  from  Iceland  and  Norway  also  provided  responses  to  the 
questionnaire. 

The  evaluation  follows  the  Commission's  Better  Regulation  Guidelines.  Accordingly,  the 
analysis  is  structured  around  the  evaluation  criteria  of  effectiveness,  efficiency,  relevance, 
coherence and EU added value. 

•  Effectiveness,  i.e.  the  evaluation  assesses  the  actual  changes  the  directive  has 
generated, particularly in view of its original objectives. In this context, the evaluation 
also  examines  how  Member  States  have  implemented  the  directive  and  how  the 
situation has evolved since the adoption of the directive; 

1   First Council Directive of 4 December 1980 on the introduction of a Community driving licence (80/1263/EEC), OJ L 375, 31.12.1980,   

p. 1. 

2   Council Directive of 29 July 1991 on driving licences (91/439/EEC), OJ L 237, 24.8.1991, p. 1. 
3   Directive  2006/126/EC  of  the  European  Parliament  and  of  the  Council  of  20  December  2006  on  driving  licences  (Recast),  OJ  L  403, 

30.12.2006, p. 18.  

4   Article 18 of Directive 2006/126/EC 
5   Article 16(2) of Directive 2006/126/EC 

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•  Efficiency,  i.e.  it  assesses  the  actual  costs  and  changes  relative  to  the  actual  benefits 
the  directive  has  generated.  Any  potential  for  simplification  and  reduction  of 
unnecessary regulatory costs is identified; 

•  Relevance, i.e. it assesses whether the objectives of the directive are still in line with 
the  current  needs  or  problems;  how  the  situation/context  as  regards  the  provisions  of 
the  directive  in  the  EU  has  evolved  and  whether  the  directive  still  matches  current 
needs; whether its scope is still fit for purpose and sufficiently able to respond to the 
evolved needs, given technological developments; 

•  Coherence,  i.e.  it  assesses  whether  the  directive  is  internally  consistent  and  whether 
the  legislation  is  consistent  with  other  EU  interventions  (as  well  as  e-governance 
initiatives);  

•  EU added value, i.e. it assesses the added value delivered by, or associated with, the 
implementation  of  the  directive,  over  and  above  what  reasonably  could  have  been 
expected from national and regional policies and their implementation. 

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2.  BACKGROUND TO THE INTERVENTION 

The first driving licence directive was introduced in December 1980 (Directive 80/1263/EEC). 
It established the Community model of driving licences and the principle of mutual recognition 
by Member States of national licences. It has also guaranteed the exchange of driving licences 
by  holders  transferring  their  place  of  normal  residence  or  place  of  employment  from  one 
Member State to another. It introduced the general principle that driving licences should only 
be  granted  to  applicants  having  passed  a  practical  and  theoretical  test  and  meeting  certain 
minimum medical standards. 

The second directive (91/739/EEC) was introduced in July 1991 and it further harmonised the 
categories of vehicles requiring different types of driving licences. It also subdivided some of 
the categories of driving licences in order to promote, in particular, access in gradual stages to 
the driving of certain vehicles in the interest of road safety. It also created specific provisions 
making  it  easier  for  physically  disabled  persons  to  drive.  It  provided  for  more  detailed 
harmonisation of the standards for driving tests and licensing. It refined the minimum standards 
of physical and mental fitness. It has allowed Member States to apply their national provisions 
on the withdrawal, suspension and cancellation of driving licences to all licence holders having 
acquired  normal  residence  in  their  territory.  It  has  also  introduced  a  standard  definition  of 
normal residence. 

The 2001 White Paper a 'European transport policy for 2010: ‘time to decide’6 placed users 
at  the  heart  of  transport  policy,  with  the  aim  of  improving  road  safety  for  road  users.  This 
White  Paper  acknowledged  that,  of  all  modes  of  transport,  transport  by  road  is  the  most 
dangerous and most costly in terms of human lives, and set the objective of reducing by 50% 
the number of deaths until 2010.  

The  European  Commission  subsequently  adopted  in  2003  the  Road  Safety  Action 
Programme  (2003–2010)7  which  confirmed  the  objective  of  halving  the  number  of  road 
accident  victims  in  the  EU  by  2010  and  proposed  a  series  of  measures  to  improve  road  user 
behaviour,  addressing  in  particular  data  collection  and  analysis,  educational  and  training 
aspects, infrastructure and vehicle safety (passive safety measures), post-accident care as well 
as enforcement. 

The  third  directive  (2006/126/EC)  was  published  in  December  2006  and  also  had  the  clear 
objective of reducing road fatalities through a set of measures8 aimed at improving road safety 
and facilitating the freedom of movement for citizens moving inside the Union.  

In 2010, after the publication of the third driving licence directive, the Commission adopted the 
policy orientations on road safety 2011-20209 that set a target of halving the number of road 

6   White Paper 'European transport policy for 2010: time to decide', COM (2001) 370 of 12.09.2001.  
7   Communication from the Commission on the European Road Safety Action Programme. Halving the number of road accident victims in 

the European Union by 2010: Aa shared responsibility, COM (2003) 311 final of 2.6.2003. 

8   Further detailed in section 2.2. 
9   Communication  from the  Commission  to the  European  Parliament, the Council, the  European  Economic and Social Committee  and the 
Committee  of  the  Regions  ‘Towards  a  European  road  safety  area:  policy  orientations  on  road  safety  2011-20202020’, COM(2010) 389 
final of 20.7.2010. 

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fatalities  by  2020  (starting  from  2010)  and  it  included  a  mix  of  initiatives  focusing  on 
improving vehicle safety, the safety of infrastructure and the behaviour of road users. 

The  2011  White  Paper  'Roadmap  to  a  Single  European  Transport  Area  –  Towards  a 
competitive and resource efficient transport system'10 further increased the level of ambition 
in  regard  to  road  safety  and  established  that  by  2050,  the  EU  would  move  towards  zero 
fatalities in road safety. It reiterated the objective of halving the number of road casualties by 
2020, making the EU a world leader in safety and security in all modes of transport.  

Faced with stagnation in the reduction of EU-wide fatality figures in the second half of the last 
decade, the Commission received a strong mandate for a new road safety programme from the 
EU Transport Ministers in the “Valletta Declaration” of 201711. 

2.1 Description of the initiative and its objectives 

The directive establishes a framework for harmonising the rules on driving licences in order to 
achieve  two  general  objectives:  to  improve  road  safety;  and  to  facilitate  the  freedom  of 
movement for citizens moving inside the Union. 

To do so, it also established the following six specific objectives: 

  Reduce,  where  possible,  the  administrative  burden  for  drivers,  administrations  and 

enforcement authorities 

  Establish uniform driving licence rules and requirements 

  Reduce the possibilities of driving licence fraud and “driving licence tourism” 

  Raise the driving skills of non-professional and professional drivers 

  Facilitate the implementation and enforcement of driving licence rules 

  To protect novice drivers.  

And ten operational objectives: 

  Establish  a  single  EU  driving  licence  model  and  ensure  its  mutual  recognition  by 

Member States 

 

Introduce the standard plastic card with a microchip 

  Facilitate  the  issuance,  renewal,  exchange  and  replacement  of  driving  licences  when 

changing residence from one Member State to another 

  Harmonise and limit the administrative validity for all new licences 

  Harmonise the periodicity of medical checks for professional drivers 

10   White Paper 'Roadmap to a Single European Transport Area – Towards a competitive and resource efficient transport system', COM(2011) 

144 final of 28.3.2011. 

11   See  https://eumos.eu/wp-content/uploads/2017/07/Valletta_Declaration_on_Improving_Road_Safety.pdf,  later  endorsed  by  the  Council 

(http://data.consilium.europa.eu/doc/document/ST-9994-2017-INIT/en/pdf).     

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  Enhance the principle of progressive access12 as regards the most powerful motorcycles 

  Harmonise the initial qualification and periodic training of driving examiners 

  Establish the principle of a single driving licence per person (1 holder, 1 licence) 

  Foster  cooperation  between  Member  States  by  establishing  the  EU  driving  licence 

network (RESPER) 

 

Introduce a driving licence category for mopeds. 

The key measures through which the  directive aims to achieve its objectives are a number of 
provisions imposing obligations on Member States to implement the directive according to the 
specific provisions mentioned in Table 1 (given in Annex 5 below). 

 

 The  intervention  logic  in  Annex  4  summarises  the  links  and  causal  relationships 
between  the  problems  and  needs.  It  takes  into  consideration  external  factors  such  as 
technological and policy developments, the general, specific and operational objectives 
that  the  legislative  framework  was  designed  to  address,  and  the  specific  actions  for 
addressing those problems and needs, as well as expected outputs, results and impacts. 

2.2 Baseline and points of comparison  

The baseline scenario is defined around the two general objectives of the directive – increasing 
road  safety  and  the  free  movement  of  citizens  –  and  is  a  projection  of  what  would  have 
happened without the adoption and implementation of any driving licence directive from 2006 
until 2018 (the “no directive” scenario).  

To do so, the baseline represents – whenever data is available – the situation as it would have 
evolved from the period before the first driving licence directive was introduced in the Member 
States in 1983, until 2018. The reason to take into consideration the three directives is to allow 
the  identification  and  quantification,  wherever  possible,  of  the  full  effects  of  the  current 
directive compared to a scenario where no directives would have existed (baseline), rather than 
being compared to the period before the current directive’s immediate introduction (when the 
second directive was in force and whose effects would be mixed with those of the current third 
directive). This approach has been taken because each revision of the driving licence directive 
has kept at least some provisions from the previous legal framework. 

The baseline scenario includes the relevant legal and socio-economic developments from 2006 
until  2018  (such  as  Directive  2003/59/EC13  on  the  initial  qualification  and  period  training  of 
truck and bus drivers, which applied in full from September 2009, and Directive 2008/96/EC14 

12 ‘Progressive access’ means that someone wishing to get alicence for a more powerful motorcycle will have to wait for two years after having 
passed the initial motorcycle test and then re-takes the test on the bigger motorcycle. Persons of a certain minimum age can be exempted 
from having to fulfil this requirement. For instance Article 4 (3) c) i) of the directive states that “The minimum age for category A is fixed at 
20  years.  However,  access  to  the  driving  of  motorcycles  of  this  category  shall  be  subject  to  a  minimum  of  two  years'  experience  on 
motorcycles under an A2 licence. This requirement as to previous experience may be waived if the candidate is at least 24 years”.   

13   OJ L 226, 10.9.2003, p. 4. 
14   OJ L 319, 29.11.2008, p. 59. 

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on road infrastructure safety management, as well as technological developments, demographic 
trends, shift in transport volumes, vehicle fleets and GDP).  

It  is  likely  that  in  the  absence  the  driving  licence  directives,  Member  States,  besides  being 
signatories of the Geneva Convention on Road Traffic15 and the Vienna Convention on Road 
Traffic16, would also have regulated driving licence rules at international level through Bilateral 
Agreements17, Memoranda of Understanding or possibly regional agreements.  

Member States would also likely have further developed national rules with different levels of 
requirements and ambition, thereby possibly achieving a lesser level of integration in terms of 
free movement and road safety, due to a lack of harmonisation and more difficult and lengthy 
mutual recognition processes of driving licences. 

Driver  behaviour  would  possibly  not  have  been  improved  across  the  European  Union  to  the 
same extent and pace without the directives, which introduced the principle of a single driving 
licence (reducing the possibilities of driving licence fraud and “driving licence tourism”).  

The  same  goes  for  skills.  In  particular,  the  provisions  regarding  the  minimum  standards  for 
driving examiners, the minimum and harmonised training obligations for novice drivers and for 
riders  of  powered  two-wheelers  would  not  have  been  in  place  without  a  common  EU 
framework,  and  the  combined  effect  of  a  plethora  of  bilateral  agreements  and  the  scattered 
national legislative actions would probably not have reached the same level of results.  

Achieving  similar  results  without  the  directives  would  have  required  significant  coordination 
among Member States but most likely this would not have resulted in a single driving licence, 
hence this would have affected the free movement of people. 

Road safety 

In terms of road safety, the baseline scenario assumes that the trends in road accident fatalities 
prior to the introduction of the directives in each Member State would have continued had there 
been no directive in force.18   

Based on this assumption, Member States that implemented the three driving licence directives 
from  1983  until  2018  (blue  line  given  in  Figure  1  in  Annex  5)  have  experienced  a  more 
pronounced  reduction  in  their  road  accident  fatality  figures  than  countries  that  had  not 
implemented the directive (orange and yellow lines).  

According  to  the  statistical  analysis19,  the  third  driving  licence  directive  may  have  had  the 
direct effect of reducing by approximately 7% the number of road accident fatalities between 

15   United Nations Convention on Road Traffic Geneva, 19 September 1949- 

https://treaties.un.org/Pages/ViewDetailsV.aspx?src=TREATY&mtdsg_no=XI-B-1&chapter=11&Temp=mtdsg5&clang=_en 

16   United Nations Convention on Road Traffic Vienna, 8 November 1968 

https://treaties.un.org/pages/ViewDetailsIII.aspx?src=TREATY&mtdsg_no=XI-B-19&chapter=11 

17   Bilateral Agreements (BAs) are concluded between Member States in written form and governed by European and/or international law. 

BAs create legally binding rights and obligations. 

18   However, a significant limitation is that the only road safety dataset available for years prior to 1983  contains only total fatality figures, 

which makes defining the baseline scenario analysis a difficult task.  

19   The statistical analysis was performed through a general linear mixed model (GLMM), with total road accident fatalities as a dependent 
variable. In order to fully exploit the database, the following variables were assumed to directly affect total fatalities and were selected to 
be included as independent variables in the model: Gross Domestic Product (GDP) per capita (in logarithmic form), the 2nd driving licence 

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2013  and  2018.  It  is  therefore  concluded  that  in  the  absence  of  the  third  driving  licence 
directive, it is likely that there would have been approximately 7% more road accident fatalities 
in  the  EU  during  this  period.  The  same  analysis  indicates  that  without  the  second  driving 
licence  directive,  fatality  rates  would  have  likely  been  higher  by  approximately  4%  overall. 
Due to data limitations, the analysis was unable to establish the effect of the first directive, thus 
the baseline without any directive in place is restricted by this limitation. 

Free movement 

Free movement of persons is supported by several EU policies adopted gradually over several 
years,  such  as  the  Schengen  agreements20  and  Directive  2004/38/EC21  on  the  right  of  citizens 
and their family members to move and reside freely within the territory of the Member States, 
and also several other EU sectoral policies.  

No data is available to develop an analysis of a baseline and therefore it is difficult to  assess 
what would have happened if no driving licence directive had entered into force. In addition, 
the  stakeholder  consultation  activities  did  not  provide  quantitative  data  to  include  in  this 
analysis.  

In  the  absence  of  a  European  framework,  the  UN  conventions  on  road  traffic22  would  have 
applied for the mutual recognition of driving licences when a driver travelled for professional 
or  recreational  purposes.  In  that  context,  drivers would  need  to  hold  an  International  Driving 
Permit (Annex 7 to the Vienna Convention, Annex 10 to the Geneva Convention) in the event 
that the Member State of issuance has not used the harmonised template for a domestic driving 
licence (Annex 6 to the Vienna Convention, Annex 9 to the Geneva Convention). Although no 
data is  available, it  can  be reasonably  assumed that  the administrative procedures required to 
obtain such a document would probably have resulted in some additional costs for the citizens 
travelling within the European Union. 

For  citizens  moving  to  other  countries  and  taking  up  their  normal  residence  there,  it  is 
reasonable  to  presume  that,  if  no  directive  had  been  in  place,  Member  States  may  well  have 
entered  into  bilateral  agreements  with  neighbouring  countries,  or  countries  from  the  same 
region, regarding the mutual recognition, exchange, renewal or replacement of driving licences. 
As a result, however, driving licence rules would likely not have been harmonised to the same 
extent  and  at  the  same  pace,  entailing  a  higher  administrative  burden  and  higher  costs  for 
citizens.  

directive and the 3rd driving licence directive and the directives on professional driver training and  on infrastructure safety management 
(2003/59/EC and 2008/96/EC). The coefficients of the variables state the elasticity and the unique effect of each variable on total fatalities. 
The reference for extracting the impact of the  2nd and 3rd directive was the situation prior to the 2nd driving licence directive (1st driving 
licence  directive  and  no  driving  licence  directive  combined)  due  to  limited  data  prior  to  the  1st  driving  licence  directive.  The  random 
effects  capture  country-level  characteristics  such  as  infrastructure,  education,  enforcement,  etc.  Robustness  of  the  GLMM  model  was 
tested (apart from the Akaike criterion of the model): observed versus predicted values were extracted and t-tests before and after were also 
made. Overall, the GLMM technique is considered to be the most appropriate for this kind of panel data. The aim of the model was to 
identify the effect of the driving licence directives on road safety outcomes in the EU countries. In order to obtain more robust results, two 
control  variables  (directly  and  indirectly  related  to  exposure),  which  have  a  significant  impact  on  road  safety  outcomes  based  on  the 
literature findings, were chosen. This is a usual technique in time series and panel data analysis. Please see Annex 3 for details. 

20   The  Agreement  of 14  June 1985  (OJ  L  239, 22.9.2000, p. 13), and  the  Convention  implementing  the  Schengen  Agreement,  which  was 

signed on 19 June 1990 and entered into force on 26 March 1995 (OJ L 239, 22.9.2000, p. 19). 

21   OJ L 158, 30.4.2004, p. 77. 
22   Please see footnotes 15 and 16 above. 

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The  existence  of  a  single  Community  Model  of  driving  licence  and  the  harmonised  validity 
periods  significantly  facilitated  the  exchange,  renewal  and  replacement  of  driving  licences  in 
the case of change of residence, compared to the situation before the directive, when more than 
110 different driving licence models existed in Europe with different entitlements and validity 
periods,  making  the  equivalence  and  recognition  decisions  more  complex.  Without  the 
directive  in  place,  different  driving  licence  models  would  most  likely  have  remained.  The 
different  legal  regimes  with  different  validity  periods  and  requirements  on  medical  checks 
would have likely created an obstacle to free movement. 

The  administrative  burden  for  Member  States  would  be  higher  compared  to  the  present 
conditions,  as  RESPER  greatly  facilitates  the  contacts  between  competent  authorities  in  the 
cases  of  first  issuance,  renewal,  and  replacement.  Drivers  would  have  been  impacted  by  the 
absence  of  RESPER,  first  because  of  the  delays  that  would  have  resulted  from  bilateral 
inquiries among Member States. In addition, Member States could also have required citizens 
to  prove  directly  their  right  to  drive,  for  instance  by  requesting  official  certificates  in  the 
country of first issuance which would have had to be translated and officially recognised, tasks 
that can become extremely burdensome when the holder of the right to drive lives in a country 
other than the one of first issuance.  

11 

 
 
 
3.  IMPLEMENTATION/STATE OF PLAY 

Directive  2006/126/EC  replaced  and  repealed  Directive  91/439/EEC  by  incorporating  in  a 
single text both the substantive amendments and the unchanged provisions thereof.   

The  transposition  deadline  of  the  directive  was  19  January  2013  and  all  Member  States 
transposed  the  directive  into  national  legislation.  However,  the  implementation  of  the 
directive  by  Member  States  has  been  subject  to  several  infringement  procedures  (see  section 
3.2). 

The  directive  has  been  subject  to  10  amendments  after  entry  into  force,  mainly  to  take  into 
account the scientific and technical progress. 

3.1 The main novelties introduced by the directive 

The main novelties introduced by the directive were the following: 

The Union model licence with advanced anti-forgery measures (Articles 1 and 3) 

The introduction of the new Union model licence was one of the changes brought about by the 
directive  and  was  introduced  by  Article  1  of  the  directive  (and  Annex  I  thereto).  The  new 
Union model licence, based on an ISO standard, has been very quickly implemented by many 
Member  States  after  the  adoption  of  the  directive  and  even  before  its  entry  into  force23.  The 
new Union model did not bring about significant changes in the organisation of the licensing 
system.  While  most  European  citizens  are  required  to  visit  a  public  administration  office  to 
apply for a driving licence, some Member States offer this service on a web platform.  

Modifications of driving licence categories (Articles 4 and 6) 

The  directive  introduced  the  EU  category  AM  for  mopeds.  According  to  the  implementation 
study24,  Member  States  used  this  introduction  as  an  opportunity  to  strengthen  their  licensing 
requirements  for  riding  a  moped,  some  Member  States  introduced  a  practical  test,  others 
introduced theoretical training, or practical training on top of the mandatory theoretical test.  

One  of  the  biggest  changes  introduced  by  the  directive  was  the  graduated  access  system  for 
motorcycles,  which  was  implemented  by  all  Member  States.  The  options  provided  by  the 
directive led to a large variation in access requirements, more so than the minimum age. 

Harmonised  administrative  validity  periods,  the  rule  of  one  single  driving  licence  per 
person and medical checks (Article 7) 

Another novelty, introduced by Article 7 of the directive, were the harmonised administrative 
introduction  of  harmonised 
validity  periods  for  all  driving 

licence  categories.  The 

23   ‘The implementation of Directive 2006/126/EC on driving licences – Final report’, drafted by Hasselt University, National Technical 
University of Athens, Austrian Road Safety Board (Kuratorium für Verkehrssicherheit) and European Transport Safety Council: 
http://publications.europa.eu/resource/cellar/bbd8141d-e603-11e7-9749-01aa75ed71a1.0001.01/DOC_1  

12 

 
                                                           
 
administration  validity  periods  aimed  at  reducing  fraud  by  allowing  regular  updates  of  the 
security  features,  facilitate  freedom  of  movement  of  EU  citizens  and  improve  road  safety  by 
introducing  mandatory  medical  checks  upon  renewal  for  holders  of  licences  C  and  D  and 
allowing Member States to introduce regular medical checks for licences A and B. 

Article 7 also introduced the principle that one holder should not be allowed to have more than 
one driving licence.  

Finally it also introduced the obligation to issue driving licences only to those having passed a 
test  of  skill  and  behaviour  and  a  theoretical  test  and  having  normal  residence  in  the  Member 
State that issues the driving licence. 

Harmonised rules on driving examiners (Article 10 and Annex IV) 

The directive introduced a set of standards for the training and education of driving examiners. 
Annex  IV  to  the  directive  contains  minimum  standards  for  driving  examiners,  including  on 
initial qualification and periodic training. 

According to  the implementation study, prior to the  directive, driving  examiners in  some EU 
countries  had  almost  no  specific  education  or  did  not  even  hold  the  driving  licence  for  the 
category that they were examining. 

EU driving licence network (RESPER) (Article 15) 

The  directive  created  an  EU  network  for  the  exchange  of  driving  licence  information 
(RESPER).  This  network  acts  as  an  EU-wide  hub  for  information  exchange  between  the 
Members  States’  driving  licence  issuing  authorities.  All  Member  States  have  connected  to 
RESPER  and  are  obliged  to  use  it.  The  main  goals  of  this  platform  are  to  ensure  the  ‘one 
person one licence’ principle, to ensure that drivers only drive vehicles in categories they are 
qualified  for  and  to  assist  Member  States  in  combating  fraud  by  allowing  them  to  verify  the 
validity of licences issued by other countries. 

3.2 Infringements related to the implementation of Directive 2006/126/EC 

The  implementation  of  the  directive  by  Member  States  has  been  subject  to  twenty-four 
infringement  procedures  for  bad  application  of  EU  law.  Twenty  two  of  those  are  closed  and 
two are still open. 

There were eighteen infringement procedures due to non-conformity (all but one25 closed due to 
corrective  measures  undertaken  by  Members  States26)  and  one  for  bad  application  of  EU  law 
(that is still open27). 

25   CZ, on Commission Directive (EU) 2016/1106. 
26   14 in connection with Directive 2006/126/EC and 3 in connection with Commission Directive (EU) 2015/653. 

13 

 
 
                                                           
3.3 Infringements  related  to  the  non-communication  of  the  transposition  of  Directive 

2006/126/EC and its amending acts. 

Directive 2006/126/EC had twenty infringement cases related to non-communication that are 
all closed due to appropriate action taken by Member States. 
Directive 2009/113/EC had sixteen infringement cases related to non-communication that are 
all closed due to appropriate action taken by Member States. 
Directive 2011/94/EU had eleven infringement cases related to non-communication that are all 
closed due to appropriate action taken by Member States. 
The  Directive  2012/36/EU  had  eleven  infringement  cases  related  to  non-communication  that 
are all closed due to appropriate action taken by Member States. 
The Directive  2014/85/EU28  has been subject  to  eleven infringements  for late transposition29, 
all currently closed due to appropriate action taken by Member States. 
Directive (EU) 2015/65330 has been subject  to  four  infringements  for late transposition31 also 
all currently closed due to appropriate action taken by Member States. 
Directive  (EU)  2016/110632  has  been  subject  to  seven  infringements.  Seven  of  those  were 
closed due to appropriate action taken by Member States. One is still open.33  
Directive  (EU)  2018/64534  amended  directives  2003/59/EC  (Article  1)  and  2006/126/EC 
(Article 2). The deadline for transposition of most provisions, including all of Article 2, was 23 
May 2020. It has been subject to sixteen infringements in relation to non-communication. Six 
infringement procedures are still open. 
Directive (EU) 2020/61235 was to be transposed into national law by 1 November 2020. It has 
been subject to 5 infringements for non-communication (all currently closed due to appropriate 
action taken by Member States). 

3.4 Judgments of the Court of Justice of the European Union 

The Court of Justice of the European Union has given several judgments36 in direct relation to 
Directive  2006/126/EC,  covering  areas  like  for  instance:  the  criteria  for  the  establishment  of 
normal  residence37,  the  mutual  recognition  of  driving  licences  in  relation  to  driving 
disqualifications and change of normal residence38, the conformity of medical fitness standards 

27   BE, on preconditions required for the exchange of driving licences issued in another Member State  that are considered in breach of the 

Union’s law (INFR 2017/4071; see also under point 5 here: https://ec.europa.eu/commission/presscorner/detail/EN/INF_20_2142). 
28   It updated some aspects of Annex II concerning minimum requirements for driving tests and added some provisions on ‘neurological 

diseases’ and on ‘obstructive sleep apnoea syndrome’ in point 11 of Annex III. 

29   The deadline for transposition was 31 December 2015. 
30   It updated Annex I (list of harmonised driving licence codes). 
31   The deadline for transposition was 1 January 2017. 
32   It updated Annex III on the points related to cardiovascular diseases and diabetes mellitus. 
33   CZ  
34   It updated Article 4 (minimum age for categories C, C1, C1E, CE, D, D1, D1E and DE and a new regime on minimum age in relation to 

the certificate of professional competence), Article 6 (possible extension of validity of category B licence for use within a Member State’s 
territory of vehicles with a maximum mass up to 4250 kg where mass in excess of 3500 kg is solely due weight of propulsion system for 
alternative fuels) and Article 15 (on the use of the driving licence network RESPER). 

35   It updated Annex II (the regime on automatic/manual transmission and the requirement on category A2 vehicles for test). 
36   Please see list of judgments in Table 6 of Annex 5. 
37   C-664/13 (ECLI:EU:C:2015:417) 
38   C-224/10 (ECLI:EU:C:2011:655), C-419/10 (ECLI:EU:C:2012:240), C-467/10 (ECLI:EU:C:2012:112), C-260/13(ECLI:EU:C:2015:257), 

C-339/14 (ECLI:EU:C:2015:333), C-9/18 (ECLI:EU:C:2019:148) and C-112/19 (ECLI:EU:C:2020:864). 

14 

 
                                                                                                                                                                                        
with  the  Charter  of  Fundamental  Rights39,  the  recognition  of  certificates  not  meeting  the 
requirements of the Union model driving licence40, the entitlement to  drive granted before 19 
January 201341, and failure of a Member State to fulfil its obligations under the directive.42  

The  court  rulings  with  particular  importance  from  an  evaluation  perspective  were  those  on 
normal  residence  (Article  12  of  the  directive)  and  on  the  cross-border  effects  of  driving 
disqualifications, in particular the impact on mutual recognition of driving licences (Article 11 
of  the  directive),  because  they  show  that  those  provisions  are  not  optimal  in  terms  of  their 
coherence (as will be elaborated in more detail in Section 5 below). The evaluation has shown 
that  the  modalities  of  application  of  Article  12  of  the  directive  need  to  be  clarified,  and  that 
Article  11,  in  relation  to  the  cross-border  effects  of  driving  disqualifications,  lacks 
effectiveness. 

39   C-356/12 (ECLI:EU:C:2014:350). 
40   C-195/16 (ECLI:EU:C:2017:815) 
41   C-632/15 (ECLI:EU:C:2017:303) 
42   C-195/16 (ECLI:EU:C:2017:815) 

15 

 
 
 
 
                                                           
4.  METHOD  

4.1 Methodology and sources of information 

The  evaluation  started  in  August  2019  and  followed  the  Commission’s  Better  Regulation 
Guidelines.43  An  Inter-Service  Steering  Group  (ISSG)  provided  advice  and  monitored  the 
progress of the exercise. Being composed of members from different Commission services and 
having the necessary mix of knowledge and experience, the ISSG brought together a range of 
different perspectives and provided the necessary input, on road safety and free movement. 

A support study was carried out by an external contractor to provide input to this evaluation.44 
In  accordance  with  the  Terms  of  Reference,  the  study  was  structured  along  seven  tasks,  as 
depicted in the Figure 2 of Annex 5. 

 The methods and tools used for the evaluation are summarised in the following paragraphs.  

The  analysis  was  structured  according  to  an  evaluation  matrix,  presented  in  Annex  4.  This 
matrix  operationalised  a  set  of  evaluation  questions  and  sub-questions,  indicators  and 
judgement criteria that would be used to answer them. It was developed on the basis of an in-
depth understanding of the directive’s intervention logic, taking in consideration what it aimed 
to achieve and how, as presented in Section 2.1 and in Annex 4. 

Review of legislative documents and reports 

In  order  to  instruct  the  evaluation  with  factual  information,  desk  research  on  several  related 
issues  was  carried  out.  The  aim  of  the  desk  research  was  to  collect,  organise  and  analyse 
relevant information from relevant secondary sources. This included statistical data, legislative 
documents, and relevant reports and studies, with the intention of collecting both quantitative 
and qualitative evidence to complement the primary evidence collected through field research.  

Field research 

The field research consisted of an open public consultation and a range of targeted consultation 
activities  detailed  in  Annex  2.  Nine  stakeholder  groups  were  consulted  in  the  context  of  the 
study, by the following means:  

A targeted survey was launched on 31 August and was open until 11 December 2020. It was 
targeted  to  a  range  of  different  stakeholder  groups,  including  national  competent  authorities, 
but also all different relevant industry sectors, associative stakeholders representing road safety 
and road users associations, drivers’ school associations, drivers’ associations, automotive and 
motorcycle  federations,  international  road  transport  associations  and  vehicle  manufacturer 
associations.  The  survey  included  questions  on  the  effectiveness,  relevance,  and  EU  added 

43   https://ec.europa.eu/info/law/law-making-process/planning-and-proposing-law/better-regulation-why-and-how/better-regulation-

guidelines-and-toolbox_en 

44   Support  Study  to  the  ex-post  evaluation  of  Directive  2006/126/EC  on  Driving  Licences  (Specific  Contract  MOVE/C2/2019-

534/SI2.826438 under framework contract MOVE/A3/2017-257) - ISBN: 978-92-76-37815-0. 

16 

 
 
 
 
                                                           
value  of  Directive  2006/126/EC.  The  questionnaire  for  national  authorities  was  answered  by 
national authorities covering all Member States except one. Two national authorities from EEA 
countries45 and Switzerland also provided responses to the questionnaire. The questionnaire for 
non-governmental stakeholders was answered by 41 participants. 

Targeted  interviews  aimed  to  complement  the  questionnaires  by  collecting  more  details  on 
why stakeholders hold certain opinions, as well as gathering additional evidence in relation to 
evaluation questions for which qualitative data was judged to be an important source. A total of 
40 interviews were planned, out of which 29 were effectively carried out with a sample of key 
stakeholders  per main stakeholder type.  The interviews included 9 representatives of national 
authorities,  13  non-governmental  stakeholders  (associations  and  other  organisations)  and  2 
representatives from the European Commission. 

A  stakeholder  workshop  was  organised  with  competent  authorities  on  16  October  2020, 
aimed at the validation and discussion of preliminary findings with the stakeholder community. 
66  participants  attended,  including  representatives  from  driving  licence  authorities,  transport 
safety associations, road user associations, driving school associations, automotive associations 
and a motorcycle federation. 

An  open  public  consultation46  was  held  from  28  October  2020  until  20  January  2021.  The 
consultation specifically  related to the  relevance,  effectiveness,  coherence, efficiency  and  EU 
added value of the directive. A total of 546 responses were received.  

Three case studies were carried out 1) on the methodology for establishing a link between the 
directive  and  its  effects  on  road  safety  and  free  movement  of  citizens,  and  quantifying  those 
effects 2) on digital driving licences and 3) on accompanied driving. 

The data collected was used to respond to the evaluation questions. All the analytical findings 
constitute  the  basis  for  the  assessment  on  how  the  directive  has  scored  on  the  evaluation 
criteria. Each of these criteria was addressed through evaluation questions, as presented in the 
evaluation question matrix presented in Annex 4.  

  4.2 

Limitations and robustness of findings 

Even though the evaluation was designed to ensure the robustness of the evidence supporting 
its  findings,  limitations  to  the  robustness  of  certain  conclusions  were  identified  while 
conducting the analysis and are inherent to this type of exercise.  

Limitations related to the COVID-19 crisis 

From a process point of view, the implementation of the ex-post evaluation has been affected 
by  COVID-19  lockdown  restrictions,  especially  for  what  concerns  the  consultation  of 
stakeholders. 

45   Iceland and Norway 
46   The  open  public  consultation  was  organised  by  the  European  Commission  and  consisted  of  an  online  questionnaire  published  on  a 
dedicated Commission webpage. It was accessible to the general public and any person interested in the topic could  submit a contribution.  

17 

 
                                                           
From a content point of view, the core analysis of the effect on road safety covers the period 
2006  up  to  2018.  Thus,  the  study  does  not  factor  in  recent  socio-economic  developments, 
specifically  in  the  wake  of  the  COVID-19  pandemic  that  had  an  unprecedented  impact  on 
transport  and  mobility  of  European  citizens,  bringing  travel  largely  to  a  standstill  for  several 
months. Unprecedented  reductions in  traffic volumes have been reported  across Europe since 
confinement  measures  associated  with  the  COVID-19  pandemic  were  introduced.47  This 
reduction  did  however  not  lead  to  a  sustained  reduction  in  road  fatalities  and,  in  some 
countries, no reductions at all because some drivers increased speed. 

Limitations concerning the stakeholder consultation 

A key source of information were stakeholder consultation activities. Several challenges were 
encountered  in  the  collection  of  data  from  stakeholders,  but  mitigation  actions  were  taken. 
Some  key  limitations  related  to  the  stakeholder  consultation  include  the  engagement  of 
stakeholders, particularly due to the COVID-19 lockdown restrictions. 

Firstly, surveys collect self-reported information from stakeholders. Therefore, this information 
may be influenced by the interests of each stakeholder or group of stakeholders, or it may be 
inconsistently reported across different groups. To address these shortcomings, information was 
triangulated to the extent possible from different sources (consultation activities, data analysis, 
legal and literature research). 

For  the  targeted  survey48  with  the  non-governmental  authorities,  41  responses  were  received 
and covered several stakeholder groups. Given the relatively limited number of responses, the 
findings  from  the  survey  of  non-governmental  authorities  are  not  considered  representative 
enough  of  the  full  population  of  non-governmental  stakeholders  that  are  affected  by  the 
directive. 

For  the  open  public  consultation,  a  total  of  546  responses  were  received,  with  a  large 
proportion  of  these  coming  from  the  Netherlands  (313).  As  presented  in  Annex  4,  this  is 
interpreted as a possible result of coordinated action of certain  categories of stakeholders. To 
overcome this limitation, the evaluation presents in a transparent manner the data sources and 
the  findings,  and  highlights  questions  where  there  was  a  high  proportion  of  stakeholders 
answering in the same or similar manner.  

Limitations concerning data availability  

Firstly, it should be underlined that there is no obligation of reporting applicable to the Member 
States. In that context, unlike other policy areas subject to an obligation of reporting, there is no 
initial set of data available for the analysis. Therefore, most of the analysis in this evaluation is 
based on stakeholder-reported views. 

47   https://etsc.eu/pin-briefing-the-impact-of-covid-19-lockdowns-on-road-deaths-in-april-2020/ 

  https://etsc.eu/pin-briefing-the-impact-of-

covid-19-lockdowns-on-road-deaths-in-april-2020/ 

48   According to task 3 of the field research. Please see Figure 4 Support Study Methodology Structure 

18 

 
                                                           
The  evaluation  takes  place  40  years  after  the  implementation  of  the  first  driving  licence 
directive and 15 years after the current directive was adopted. This long timespan has important 
implications in terms of data availability for defining the baseline scenario, which gives rise to 
limitations in terms of the measurability of effects, outcomes, results, costs, and benefits arising 
from the directive. To overcome this lack of data, some assumptions had to be made, relying on 
desk  research,  consultation  of  stakeholders  and  results  of  statistical  analysis  of  road  safety 
trends, which strives to ensure that the results are as robust and credible as possible. 

Concerning  the  analysis  of  the  effect  of  European  driving  licence  rules  on  road  safety 
(effectiveness), statistics on road accident fatalities are available from 1970 until the present but 
only as total figures. Although providing robust evidence, the statistical modelling has several 
limitations,  since  road  safety  can  be  affected  by  many  factors  beyond  the  driving  licence 
directives (such as legislative, policy49, technological and demographic factors). However, not 
all  policies,  programmes  and  actions  can  be  included  in  statistical  models,  as  they  are  not 
specific directives or guidelines that Member States would implement. In order to mitigate this 
limitation, the effects of such factors on road safety developments were taken into account and 
statistically  estimated50  together  with  all  other  developments  not  included  in  the  model  as 
separate variables (e.g. vehicle technology, road infrastructure, legislative changes etc.).  

Concerning  the  contribution  of  the  directive  to  facilitating  free  movement  across  EU  for  EU 
citizens  (EQ  1),  literature  concerning  the  movement  of  persons  across  borders  in  relation  to 
driving licence rules is very limited and mostly providing qualitative assessments of the extent 
to which the two are related. Similarly, statistical data on this is not available to monitor and 
assess the trends over time and the effect of the directive on free movement. This constitutes a 
key  limitation  of  the  analysis.  To  mitigate  this  limitation,  qualitative  evidence  was  collected 
through stakeholder consultation to ascertain the perceived effect that the directives had.  

Concerning the assessment of the impact of the directive on driving licence tourism and driving 
licence  fraud  (EQ  2.3),  one  key  limitation  is  that  there  are  no  consistent  statistics  on  driving 
licence  fraud.  The  assessment  made  was  essentially  qualitative  based  on  interviews  and 
stakeholders’ answers to EQ 2.3 in the surveys with national authorities and non-governmental 
stakeholders. 

Concerning  the  analysis  of  the  effect  of  the  absence  of  a  common  framework  on  driving’ 
disqualifications  on  road  safety  (EQ  6),  data  on  the  frameworks  in  place  in  countries  that 
mutually  recognise  disqualifications  was  not  made  available  in  the  data  collection  processes. 
Nevertheless,  the  analysis  is  still  robust  to  some  extent,  as  it  relies  on  evidence  collected 
through  desk  research  (e.g.  analysis  of  Court  of  Justice  rulings)  as  well  as  comprehensive 
consultation activities.  

49   For  instance,  the  Road  Safety  Action  Programme  (2003-2010)  (COM(2003)  311),  the  Communication  providing  policy  orientations  on 
road safety for the period 2011-2020 (COM(2010) 389) and, most recently, the Valetta Declaration of 2017 and the EU Road Safety Policy 
Framework 2021 -2030 – Next steps towards 'Vision Zero' (SWD(2019) 283). 

50   This was done through the random effects of the model. 

19 

 
                                                           
The analysis of efficiency (EQ 9 – 11) is relying on data collected via several data collection 
streams, including desk research and surveys of national authorities. Limitations concerning the 
analysis  concern  the  lack  of  availability  of  data  related  to  the  precise  costs  and  the 
administrative burden associated with the directive. The analysis is essentially quantitative with 
diverging views between national authorities who consider that the administrative burden and 
costs  been  reduced,  while  citizens  do  not  seem  to  have  perceived  that  reduction  in  the  costs 
incurred by them. 

20 

 
 
 
5.  ANALYSIS AND ANSWERS TO THE EVALUATION QUESTIONS 

This  section  provides  the  analysis  and  the  results  for  the  five  evaluation  criteria  of 
effectiveness, efficiency, relevance, coherence, and EU added value. 

The findings presented are based on the results from desk research, as well as results obtained 
through stakeholder consultations. 

5.1  Effectiveness 

This  subsection  assesses  whether  the  directive  has  been  effective  in  achieving  the  intended 
objectives (as described in the intervention logic). When analysing the answers to the questions 
in this section, they were grouped under the heading of the objective to which they relate. 

5.1.1  General objectives 

5.1.1.1 

Enhancing road safety 

Relevant questions to assess the effectiveness in reaching this objective: 

EQ 1 What have been the effects of the directive in terms of enhancing road safety? 

EQ 7 Which factors have contributed to/hindered the achievement of objectives? 

The analysis suggests that the directive had a twofold impact on the reduction of road fatalities, 
a general one across all road users, and a more intense one in specific categories of road users 
as detailed below. The statistical analysis indicates that the (third) directive may have led to an 
overall reduction of approximately 7% in the number of fatalities compared to the baseline and 
to the effect of the first directive.51  
There  is  however  little  evidence  –  most  stakeholder  views  suggest  that  road  safety  has  been 
positively affected by several factors such as protecting young drivers and improving the skills 
of non-professional drivers. The fulfilment of several operational objectives of the directive is 
also seen by some stakeholders to have made a positive contribution to road safety, such as the 
harmonisation  of  minimum  standards  for  driving  examiners  including  quality  assurance  and 
regular periodic training, minimum testing requirements for drivers, medical examinations for 
professional  drivers,  minimum  age  per  category,  and  the  progressive  access  to  category  A 
driving licences. On the other hand, the analysis suggests that road safety has been hindered by 
the absence of an EU framework for the mutual recognition of driving disqualifications. 

To  answer  these  evaluation  questions,  we  have  based  the  analysis  on  road  safety  data  that 
underwent a statistical analysis (as explained in Annex 3), and also information received from 
the targeted stakeholder consultation and the Open Public Consultation. 

51    Due to data limitations, the statistical model could not separate the effect of the first directive from the “no directive” baseline for this part 

of the analysis. 

21 

 
 
 
                                                           
The  first  key  objective  of  the  driving  licence  directives  is  to  improve  road  safety,  and  the 
obligation  to  hold  a  driving  licence  is  a  key  requirement  of  all  safe  road  transport  systems, 
implying that drivers acquire the ability and motivation to drive competently and unimpaired. 
The  licensing  system  is  the  main  method  for  jurisdictions  to  meet  their  obligations  to  ensure 
that all drivers are medically fit and able to drive independently, competently, and safely52.  

As mentioned in section 2.1 the directive has introduced several measures aimed at increasing 
road  safety:  For  instance,  professional  drivers  have  to  periodically  prove  compliance  with 
minimum  standards  of  physical  and  mental  fitness  for  driving  (first  issuance  and  renewal  of 
driving  licences).  The  directive  also  harmonised  administrative  validity  periods53  and 
introduced medical checks upon licence renewal for non-professional drivers reaching a certain 
age. 

The directive also enforced the principle of progressive access to the most powerful categories 
of two-wheeled vehicles and to vehicles used for the transport of passengers and goods. It has 
also  introduced  a  driving  licence  category  for  mopeds  targeting  in  particular  the  youngest 
drivers who, according to the statistics, are the most affected category by road accidents. It has 
harmonised the initial qualification and periodic training of driving examiners, which indirectly 
led also to an overall raise of the quality of training and knowledge of all drivers54.  

It has introduced the principle of a single driving licence per person and fostered cooperation 
between Member States  by  establishing the  EU  driving licence network  (RESPER), allowing 
the reinforcement of the licensing system. 

The directive is also likely to have had a positive impact on elderly drivers’ and professional 
drivers'  fatalities,55  due  to  harmonised  administrative  validity  periods  and  the  introduction  of 
medical  checks  upon  licence  renewal  for  the  elderly  and  also  the  harmonisation  of  the 
periodicity of medical checks and training for the professional drivers. 

The findings of the statistical analysis are reinforced by the findings from the targeted surveys 
and interviews, and the results of the open public consultation.  

The targeted survey with national authorities indicates that, in instances where authorities could 
make an assessment, the majority of the respondents assessed that the directive had a positive 
effect  on  reducing  road  accidents.  11  out  of  the  32  national  authorities  that  provided  an 

52   European Commission (2017), Study on driver training, testing and medical fitness. Report drafted by TRL, SWOV, BASt, Loughborough 

University, Monash University. 

53   Detailed data in Annex 5 with the situation per Members States on validity periods. 
54   According  to  the  implementation  study  which  was  part  of  the  literature  review  used  in  the  evaluation,  11  out  of  20  Member  States 
authorities considered that the current provisions of the directive on driving examiners have had a positive effect on road safety, whereas 9 
out of 20 expressed no opinion. The results from the targeted survey with national authorities also showed that the provisions on minimum 
standards for driving examiners are important for improving road safety. This finding was confirmed during the interviews with national 
authorities. In the survey with non-governmental stakeholders, the minimum standards for driving examiners including quality assurance 
and periodic training were considered to be one of the most important provisions for road safety (34 out of 41 respondents).  

55   A large proportion of national authorities (between 70-90% of 32 national authorities) could not make an assessment of the effect of the 
directive  on  specific  categories  of  road users,  such as  older  drivers.  Amongst  those  that could provide  a  response,  6  out  of  32 national 
authorities  (EE,  ES,FI,GR,  LV  and    LT)  claimed  that  the  directive  had  a  positive  effect  on  road  safety  for  older  drivers,  and  the  same 
number for professional drivers' fatalities (EE, ES, FI, GR, LT and PL). 

22 

 
                                                           
answer56,  and  30  out  of  41  of  the  non-governmental  stakeholders,  positively  assessed  the 
contribution that the directive had on road safety. Furthermore, in the interviews, 9 out of the 9 
national  authorities57  and  7  out  of  13  non-governmental  stakeholders  generally  assessed  the 
directive as having a positive effect on road safety. In the open public consultation 362 out of 
546 stakeholders shared the same view. 

In  the  survey  with  national  authorities,  one  third  of  national  authorities58  claimed  that  the 
contributed to road safety improvements, but it is not easy to calculate the precise contribution 
as  other  factors  (other  legislative  actions,  better  enforcement,  improvements  on  road 
infrastructure,  education,  standards  of  the  roads,  campaigns,  more  secure  vehicles  etc.)  may 
also  have  had  a  substantive  impact  on  improved  road  safety  figures.  The  Swedish  national 
authority  highlighted  that  the  increased  age  limit  for  category  A  could  have  affected  the 
accident rates related to  motorcycles with  young drivers, which  would then lead to a positive 
effect on road safety. Full details of the stakeholders’ positions are in detailed in Annex 2. 

5.1.1.2 

Facilitating free movement for EU citizens  

Relevant questions to assess this objective: 

EQ 1 What have been the effects of the directive in terms of facilitation free movement? 

EQ 7 Which factors have contributed to/hindered the achievement of objectives? 

The  analysis  seems  to  indicate,  mostly  based  on  stakeholder  views,  that  several  of  the 
directive's  provisions  had  a  positive  effect  on  free  movement.  The  provisions  that  have  been 
particularly relevant are the mutual recognition of driving licences in the EU, the harmonisation 
of  driving  licence  categories  and  vehicles  definitions,  the  Union  model  driving  licence, 
RESPER and the minimum age limits per category.  
On the other hand, the provisions on normal residence, the absence of a framework for a mutual 
recognition of driving licences issued in third countries, and the fact that the directive allowed 
for the very prolonged use of some old driving licence models (until 2033), were considered as 
factors responsible for hindering the objective of enhancing free movement. 

The facilitation of free movement of citizens inside the EU is the second general objective of 
the directive. It is difficult to isolate and determine the specific effects of the directive on the 
facilitation of free movement, from the effects emerging from other policies or measures also 
impacting free movement. After the full entry into force of the directive there was an increase 
in  the  number  of  citizens  moving  cross-border  within  the  European  Union  but  the  relation 
between  these  movements  and  the  driving  licence  framework  cannot  be  established.  Internal 

56   Note that the remaining 21 respondents were not able to make an assessment. No respondent made a negative assessment.  
57   Although the precise level of effect is difficult to estimate as they considered that the improvement in road safety was not  due solely to 

Directive 2006/126/EC. 

58   FI, FR, GR, IE, LT, PT, SE, SI, SK and Norway. 

23 

 
 
 
 
                                                           
mobility in the EU is likely to have been influenced by factors other than the driving licence 
rules, although the simplification of certain rules related to driving licences introduced by the 
Third  driving  licence  directive  is  likely  to  have  contributed  to  increased  movement  of  EU 
citizens.  The  analysis  below  provides  a  qualitative  assessment  of  the  extent  to  which  the 
provisions of the directive could have contributed to the achievement of this objective.  

The  implementation  report59  found  that  the  union  model  licence  and  the  rules  on  mutual 
recognition  of  licences  between  Member  States  have  simplified  the  complex  framework  that 
was  in  place  prior  to  the  introduction  of  the  directive.  Before  the  directive,  there  were  more 
than  110  different  driving  licence  models  with  different  entitlements  and  validity  periods  in 
Europe.  The  directive  simplified  this  patchwork  and  made  the  exchange  of  driving  licences 
easier, thus  facilitating the mobility of drivers. The same report  also highlighted that the new 
model was considered more practical, durable, resistant, more convenient in terms of use, and it 
facilitates  a  greater  freedom  of  movement  for  licence  holders  by  improving  the  transnational 
acceptance of the driving licences. 

In  the  targeted  survey,  the  majority  of  national  authorities  (21  Member  States  and  2  EEA 
countries60)  considered  that  the  third  driving  licence  directive  and  the  former  driving  licence 
directives contributed to the free movement of citizens within the EU.  

Nevertheless,  9  national  authorities  mentioned  they  could  not  make  an  assessment  and  one 
mentioned that the system is increasingly complex due to many exceptions, acquired rights and 
usage of national codes. 61  

The  targeted  survey  with  non-governmental  stakeholders  also  indicates  that  the  directive 
contributed to the free movement of citizens. Especially the provisions on mutual recognition, 
harmonised  driving  licence  rules  and  vehicle  definitions  (for  39  out  of  41  respondents62),  the 
Community Model of driving licences (for 35 out of 41 respondents63) and the minimum age 
categories (for 30 out of 41 respondents64). 

In the Interviews, 8 out of 9 of the national authorities65 indicated that the directive facilitated 
the free movement of EU citizens. They mentioned that mutual recognition and harmonisation 

59   European Commission (2017), The implementation of  Directive 2006/126/EC on driving licences. Report drafted by Hasselt University, 

NTUA. 

60   Member States: BG, BE, CZ, CY, DK, EE, ES FI, FR, GR, DE, LV, LU, MT, PL, PT, SK and SI; EEA countries: Iceland and Norway.  
61   NL In the targeted survey stated that the directive did not contribute to improved free movement of citizens within the EU since mutual 
recognition was already in the  2nd driving licence directive but many exceptions and acquired rights in the different Member States and 
national codes make the system increasingly complex. However NL in the interviews with national authorities mentioned that the directive 
had a very positive contribution to the free movement of EU citizens because of mutual recognition of driving licences and the EU single 
model of driving licences.  

62   6 automotive and motorcycle federations, 2 drivers associations, 7 drivers school associations, 2 international road transport associations, 

10 road safety and road users associations, 2 vehicle manufacturer associations, 10 'other category'. 

63   4 automotive and motorcycle federations, 3 drivers associations, 6 drivers school associations, 2 international road transport associations, 
10  road  safety  and  road  users  associations,  9  road  safety  and  road  users  associations,  2  vehicle  manufacturer  associations,  10  other 
category.  

64   4 automotive and motorcycle federations, 2 drivers associations, 5 drivers school associations, 2 international road transport associations, 7 
road safety and road users associations, 8 road safety and road users associations, 2 vehicle manufacturer associations, 7 'other category'. 

65   BE, BG, DE, DK, ES FI, GR and NL. 

24 

 
                                                           
facilitated  the  usage  and  exchange  of  driving  licences  across  the  European  Union.  RESPER 
facilitated verification of validity, exchanges and enforcement. 

Similarly, 8 out of 13 non-governmental stakeholders indicated in interviews that the directive 
has facilitated the free movement of EU citizens66. 

In the Open Public Consultation, 69% of the respondents (i.e. 378 respondents) considered the 
directive to have been a relevant tool for the free movement of non-professional drivers, either 
to a great extent or somewhat; whereas 63% (i.e. 344 respondents) considered the directive to 
have been a  relevant  tool either to  a  great  extent or somewhat  when it comes to  professional 
drivers. 

Despite  this  positive  contribution,  the  implementation  report  and  certain  assessments  from 
stakeholders  showed  that  the  rules  on  normal  residence  pose  challenges67  together  with  the 
absence of a framework for the mutual recognition of third country driving licences68.  

5.1.2  The specific objectives 

5.1.2.1 
enforcement authorities” 

Objective “Reducing administrative burden for drivers, administrations and 

Relevant questions to assess this objective 

EQ 2.1 To what extent has the administrative burden for drivers and Member States been reduced? 

EQ 7 Which factors have contributed to/hindered the achievement of objectives? 

The  findings  of  the  analysis  are  mixed  when  it  comes  to  the  reduction  of  the  administrative 
burden.  Based  on  stakeholder  views,  the  administrative  activity  of  issuing,  renewing  or 
replacing  driving  licences  seems  to  not  have  been  affected,  or  even  become  less  labour 
intensive under the directive.  

Nevertheless  some  control  activities  that  intervene  at  the  moment  of  issuing,  renewing  or 
replacing of driving licences (like medical exams), or the introduction additional requirements 
(e.g;  graduated  access)  and  shorter  validity  periods  are  perceived  by  citizens  as  having 
increased their administrative burden. 

The  directive  introduced  several  provisions  that  can  be  associated  with  either  an  increase  or 
decrease  in  the  administrative  burden  of  the  relevant  authorities  and  citizens.  These  include 

66   FIA, IFMC, IRU, ACEM, FEMA, STR, CIECA and BFV.  
67   In the survey  with national authorities:  AT,  BG, BE, CY, DK, FI, DE, GR, IT,  IE,  LV,  LU,  LT, NL, RO, SK, SI, ES, SE and Norway 
indicated that there are some challenges related to the definition of normal residence and the 185-days rule foreseen in the driving licence 
directive. The problems related to the definition of normal residence are fully detailed in section 5.1.2.7 (Positive and negative unexpected 
effects of the directive) and those related to absence of a framework for mutual recognition for third country driving licences  in section 
5.1.2.2 (under the heading Exchange of driving licences between Member States). 

68   In the survey with national authorities: 18 respondents mention as an obstacle (BG, BE, DK, FI, GR, HU, IE, LV, LU, NL, PL, PT, RO, SI, 

ES, SE, Iceland and Norway). 

25 

 
 
 
                                                           
RESPER,  the  new  EU  driving  licence  model  and  mutual  recognition  of  the  common  driving 
licence  across  Member  States,  the  introduction  of  harmonised  administrative  validity  periods 
and the introduction of progressive access to category A licences.  

The following sections present the key findings concerning the extent to which the provisions 
of  the  directive  had  a  positive  or  negative  impact  on  administrative  burden  for  relevant 
stakeholders,  compared  to  the  situation  prior  to  that  (covering  the  second  driving  licence 
directive). 

The  analysis  indicates  that  the  establishment  of  a  network  between  Member  States  for  the 
exchange of information on driving licences (RESPER) had a positive effect on the reduction 
of the administrative burden, as it is much easier and faster to exchange information between 
Member  States  and  to  verify  the  authenticity  of  driving  licences  when  issuing,  renewing  or 
replacing driving licences. If this tool did not exist, the burden of proof would rely on citizens 
who  would  have  to  prove  the  existence  of  their  rights  to  drive  via  alternative  means.  The 
common model of driving licences and the principle mutual recognition of driving licences are 
also  perceived  as  reducing  the  administrative  burden  of  citizens,  when  issuing,  renewing  or 
replacing of driving licences.  

The implementation study69 indicates that the administrative burden has gradually been reduced 
with the introduction of the common driving licence by the directive, as well as the principle of 
mutual  recognition70.  The  same  study  indicated  a  strong  trend  towards  digitisation  of  data 
storage and transfer as well as a decrease in paperwork. According to this study, the assumption 
of the decrease of the administrative burden is supported by a decreasing number of employees 
occupied with processing driver licence applications by the issuance authorities.  

In  the  survey  with  national  authorities  12  out  of  2071  indicated  that  the  processing  time  for 
issuing, exchanging, replacing, and renewing driving licences remained the same, while 6 had 
the opposite view. 

Non-governmental  stakeholders  assessed  that  the  procedures  for  non-professional  driving 
licences have become less complex and costly as compared to the procedures for professional 
drivers.  

The results of the open public consultation indicate that the overall perception of stakeholders 
is that the directive has reduced the administrative burden for drivers when travelling by road 
through another Member State. 

The  implementation  study72  indicates  that  the  shorter  validity  periods  and  additional 
requirements  (e.g.  medical  checks  for  professional  drivers)  are  associated  with  higher 
administrative burden for drivers.  

69   European Commission (2017), The implementation of  Directive 2006/126/EC on driving licences. Report drafted by Hasselt University, 

NTUA. 

70   Dating back to the 2nd driving licence directive but continued in the  3rd directive. 
71   AT, CZ, DE, IT, LV, LT, LU, NL, SK, SI, ES, SE. 

26 

 
                                                           
Stakeholders consulted in the targeted consultation (7 out of 9 interviewed national authorities, 
9  out  of  13  interviewed  non-governmental  stakeholders),  as  well  as  in  the  open  public 
consultation  (196  out  of  546  respondents)  point  to  the  fact  that  the  rules  on  administrative 
validity periods have led to higher administrative burden, particularly  for professional drivers. 
However,  some  stakeholders  (5  out  of  13  interviewed  national  authorities)  have  also 
acknowledged that the benefits of the harmonisation outweigh the additional burden.  

In the targeted survey with non-governmental stakeholders, 16 of 36 agreed or strongly agreed 
that  graduated  access  may  have  increased  the  administrative  burden  for  driving  schools  and 
instructors. 5 disagreed, and 14 could not make an assessment.   

In the interviews with national authorities, 573 out of 9 stated that graduated access resulted in 
higher  waiting  times  for  obtaining  a  licence.  The  interviews  with  the  non-governmental 
stakeholders confirmed the same finding74. On the other hand, some stakeholders75 perceived 
that the costs related to the progressive access to category A driving licence are justified due to 
the benefits for road safety. This point will be further developed in the efficiency section (5.2)76 

5.1.2.2 

Objective “Establish uniform driving licence rules and requirements” 

Relevant questions to assess this objective: 

EQ  2.2  In  which  areas  (e.g.  validity  periods,  medical  exams,  training  or  testing)  have  uniform  driving  licence 
rules and requirements been established across MSs? In which areas are there still divergences? 

EQ 5 What has been the impact, if any, of differences across Member States regarding the recognition of driving 
licences issued by third countries, for example in relation to driver shortage for EU hauliers? 

EQ 7 Which factors have contributed to/hindered the achievement of objectives? 

The  analysis  shows  that  several  uniform  rules  and  requirements  were  implemented  in  the 
Member  States  as  a  consequence  of  the  directive,  allowing  for  greater  convergence  and  a 
greater  degree  of  harmonisation.  Harmonised  requirements  on  mutual  recognition  of  driving 
licences, administrative validity periods, competence of driving examiners and medical checks 
are perceived as particularly beneficial. However, some differences still exist, particularly when 
it  comes  to  the  application  of  exemptions  for  certain  categories  of  drivers  (novice  and  older 
drivers) and the issuance of driving licences upon expiry of administrative validity periods. 

Administrative validity periods 

72   European Commission (2017), The implementation of  Directive 2006/126/EC on driving licences. Report drafted by Hasselt University, 

NTUA. 

73   BE, NL, FI, GR and DK. 
74   Both  FEMA  and  ACEM  noted  that  the  licencing  system  is  complex.  FEMA  also  highlighted  that  the  system  is  not  supporting  of  the 

objectives of the driving licence directive to reduce administrative burden, as licencing expensive and complex 

75   BVF, STR and FIA. 
76   Question 9 “Has the directive resulted in any excessive costs / negative impacts?” 

27 

 
 
 
 
                                                                                                                                                                                        
The evaluation indicates that an increased harmonisation of administrative validity periods has 
been  achieved  as  a  result  of  the  directive,  but  not  a  total  harmonisation  due  to  the  flexibility 
given to Members States by certain provisions of the directive. 

Article  7  of  the  directive  lays  down  the  provisions  for  administrative  validity  periods.  The 
directive  stipulates  that  driving  licences  for  categories  A  and  B  shall  have  an  administrative 
validity  period  of  10  years,  but  Member  States  may  choose  to  issue  such  licences  with  an 
administrative  validity  period  of  up  to  15  years.  The  directive  further  stipulates  that  driving 
licences for categories C and D have an administrative validity period of 5 years. According to 
the directive, the renewal of a driving licence upon expiry of the administrative validity period 
is subject to: continuing compliance with the minimum standards of physical and mental fitness 
for driving set out in Annex III and normal residence in the territory of a Member State issuing 
the licence. The directive lays down that when renewing driving licences in categories A and B, 
Member States may  require an examination applying the minimum  standards of physical  and 
medical  fitness  set  out  in  Annex  III  to  the  directive.  The  directive  allows  Member  States  to 
limit the administrative validity  period when it comes to  novice drivers and drivers that have 
reached the age of 50 with the aim of improving road safety. 

The  implementation  study,  pointed  to  several  differences  still  remaining  particularly  when  it 
comes to the issuance of driving licences upon expiry of the administrative validity period, the 
application  of  exemptions  for  certain  categories  of  drivers  (novice  and  older  drivers)  and 
administrative validity periods of 10 and 15 years for driving licence categories A-B and of 5 
years for driving licence categories C-D.  

According to the results of the above mentioned study and the survey results77, most countries 
(19  out  of  30)  chose  a  validity  period  of  10  years  for  driving  licences  categories  A-B.  11 
countries  have  adopted  an  administrative  validity  period  of  15  years  for  driving  licence 
categories A-B.  

Another  specificity  is  that  some  countries  have  limited  administrative  validity  periods  for 
novice  drivers,  while  others  do  not  have  such  limited  validity  periods.  Some  countries 
implement a sort of a probation/ trial period or a limited administrative period. For category A 
or B licences a limited period of 2 or 3 years is applied by some countries. 

Medical checks  

The information  gathered in  the desk review, the stakeholder survey  and interviews indicates 
that there may be an increased harmonisation of medical checks since the entry into force of the 
directive,  particularly  when  it  comes  to  professional  drivers,  but  that  differences  still  remain 
due to the flexibility given to member states. 

Annex  III  to  the  directive  sets  out  minimum  standards  of  physical  and  mental  fitness  for 
driving. The directive requires that the minimum standards be checked by Member States when 
issuing  a  driving  licence.  Member  States  may  impose  stricter  standards  if  deemed  necessary. 

77   The survey results did not cover MT, PT, United Kingdom and the response from the Czech national authority was considered invalid, as 

they claimed an unrestricted validity period even though this is not in line with the driving licence directive. 

28 

 
                                                           
The directive allows Member States to apply increased frequency of medical checks for certain 
categories of drivers (novice and older drivers). The directive also requires that Member States 
check continued compliance with the minimum standards in Annex III when renewing driving 
licences  in  categories  C  and  D.  Member  States  may  also  apply  an  examination  to  check 
requirements with Annex III when renewing licences in categories A and B.  

These standards are considered as one of the most relevant measures for road safety according 
to some stakeholders78. One non-governmental stakeholder79 mentioned that maybe some more 
harmonisation should be considered in this area. 

Some  differences  between  Member  States  still  remain,  particularly  when  it  comes  to  the 
application  of  medical  checks  for  persons  with  medical  conditions  and  for  older  drivers  as 
explained below. 

According to the implementation study80 there is a significant variation in medical checks when 
renewing  non-professional  driving  licences  (A  and  B).  Two  thirds  of  the  Members  States 
required  no  medical  examination  at  renewal,  while  only  one  third  required  a  medical 
examination.  

For  professional  driving  licence  categories  (C-D),  almost  all  countries  ask  for  some  sort  of  a 
medical examination upon renewal and in a few instances, a medical examination upon renewal 
was only required at a certain age of a driver. Two Member States indicated having a time limit 
for the renewal of professional driving licences.  

Training and testing requirements 

The analysis highlights that training and testing practices and requirements vary across Member 
States  and  the  degree  of  harmonisation  is  low.  The  directive  only  provides  minimum 
requirements  and  leaves  it  up  to  the  Member  States  to  establish  specific  requirements  and 
procedures for training and testing.  

Annex II to the directive provides minimum requirements for driving tests, whereas Annex VI 
provides minimum requirements for driver training and testing for motorcycles within category 
A  (progressive  access).  However,  beyond  providing  minimum  requirements,  the  directive 
leaves it up to the Member States to establish specific requirements and procedures for training 
and  testing.  As  a  result,  training  and  testing  practices  and  requirements  vary  across  Member 
States.  

A first important variation is between the nature of the driver training which can be formal or 
informal81.  In  most  Member  States,  learner  drivers  can  prepare  for  the  practical  driving  test 
only  by  taking  formal  driving  lessons  from  a  professional  driving  instructor.  Some  Member 
States allow learner drivers to take only informal driving training in preparation for the driving 

78   In  the  targeted  survey  when  replying  to  EQ7  “Which  factors  have  contributed  to/hindered  the  achievement  of  objectives?”  non-
governmental stakeholders considered that the enforcement of harmonised medical checks is one of the most important measures for road 
safety. 

79   IRU 
80   European Commission (2017), The implementation of Directive 2006/126/EC on driving licences. Report drafted by Hasselt University, 

NTUA. 

81   Formal training is tuition based and is provided by a qualified instructor. Informal training can be done in instances where the learner gains 

experience while supervised by an experienced driver.  

29 

 
                                                           
test  (typically  with  a  parent)82.  A  few  Member  States  have  a  dual  licencing  system,  meaning 
that  learner  drivers  take  a  combination  of  formal  and  informal  training83.  In  all  cases  where 
informal training is allowed, the appearance of electric vehicles can create problems as they all 
don’t have gears and therefore cannot be used to provide complete informal training. 

Informal on-road driver training is allowed in 12 Member States before the driving test, 
whereas in 2 Member States it is allowed after the driving test.84  

Variations are also found in terms of mandatory or optional theoretical training and whether a 
fixed  number  of  lessons  is  required  prior  to  testing.  According  to  the  2017  European 
Commission study on driver training, testing and medical fitness85, theory training is mandatory 
in 18 Member States and optional in 9 Member States.86 

The  targeted  survey,  the  interviews,  and  the  2017  European  Commission  study  on  driver 
training, testing and medical fitness87 showed that national curricula differ, including on the use 
of a multi-stage training and post-test courses.  

According to this study the majority of the countries imposes a mandatory and fixed number of 
theory training lessons and formal on-road driver training. The majority of countries have also 
mandatory formal on-road training88.  

Only  2  Members  States  included  hazard  perception  and  risk-/  self-assessment  skills  in  their 
curriculum89.  

The  stakeholder  consultation  showed  that  there  are  several  national  specific  requirements 
related to training and testing of novice drivers (e.g. topics addressed in the exam, number of 
questions,  regulation  of  price  of  training  and  theory  courses).  Stakeholder  views  vary 
concerning  the  need  to  harmonise  training  obligations.  Some  stakeholders  indicate  that  the 
absence of a harmonised framework  for training  has implications on the  skills  of drivers  and 
road safety, whereas other stakeholders point to the need to allow flexibility to Member States 
to accommodate their national specificities in defining training curricula. 

The  results  of  the  consultation  activities  indicate  that  approximately  half  of  stakeholders 
consider the directive had a positive effect on the increase of driving skills, particularly when it 
comes to professional drivers. 90 

82   BE (the 36 months training option) and FI. 
83   BE (the 18 months training option), DE, FI, FR and DE  
84   Before test: AT, BE, CY, EE, FI, FR, IE, LT, LV, LU, PT and SE. After driving test: DE and NL. 
85   European Commission (2017), Study on driver training, testing and medical fitness. Report drafted by TRL, SWOV, BASt, Loughborough 

University, Monash University. 

86   Mandatory: AT, BG, HR, CZ, DK, EE, FI, DE, GR, HU, LV, LT, LU, PL, PT, SK, SI. Optional: BE, CY, FR, IE, IT, MT, NL, ES, and 

SE. 

87   European Commission (2017), Study on driver training, testing and medical fitness. Report drafted by TRL, SWOV, BASt, Loughborough 

University, Monash University. 
88   But 5 do not CY, IT, MT, ES and SE. 
89   DE and NL. 
90   Concerning the skills of professional drivers, a substantive proportion of national authorities consulted in the survey (18 out of 32) could 
not  make  an  assessment,  but  the  remainder  (13  out  of  32)  made  a  positive  assessment.  In  the  targeted  survey  with  non-governmental 
organisations, just over a half of the 41 surveyed non-governmental stakeholders perceived that the directive led to improved driving skills 
of professional and non-professional drivers. 

30 

 
                                                           
Requirements for obtaining category AM driving licence 

On the requirements  for  obtaining category AM  driving licences, the directive  seems  to  have 
brought a large degree of harmonisation, but not complete harmonisation.  

Concerning  the  requirements  for  obtaining  a  category  AM  driving  licence,  the  directive 
introduced the category of mopeds and an obligation to pass a theoretical test. Member States 
have the option to also require a test of skills and behaviour and a medical examination for this 
category, but it is not mandatory. 

Although the directive only requires that applicants pass a theoretical test, the vast majority of 
Member States have implemented theoretical and practical tests and practical training, but not 
all  Members  States  did  so91.  There  are  still  specific  national  requirements  in  place  for  this 
category92.  

Requirements for obtaining a category A driving licence 

On  the  requirements  for  obtaining  a  category  A  driving  licence,  the  directive  seems  to  have 
effected a large degree of harmonisation but not complete harmonisation. 

The  directive  has  set  that  the  minimum  age  to  accede  to  a  category  A  driving  licence  at  20 
years old provided the applicant has held for at least two years an A2 driving licence (a licence 
for less powerful motorcycles). This staging requirement may be waived if the candidate is at 
least 24 years old. 

The category A driving licence can be obtained through direct access in most countries but not 
all.93 

Practical  testing  requirements  are  now  demanded  by  26  national  authorities  compared  to  23 
prior to the implementation of the directive.  

Theoretical 
training 
implementation of the directive94.  

is  currently 

implemented  by  18  surveyed  countries,  since 

the 

Theoretical  and  practical  testing  are  in  force  in  all  the  countries.  3  Members  States95  have 
introduced practical tests with the implementation of the directive. 

91   Currently, theoretical test is implemented in 26 Member States, GR is the only country without a theoretical test for this driving category. 
The total number of countries imposing practical test climbed to 21 countries, with 6 additional countries after the implementation of the 
directive (FI, HU, LV, ES, RO, and EE).  

92   For instance AT imposes medical checks from the age of 20, and DE asks for an eyesight test, and in FI the practical test can be conducted 
only with light four-wheel vehicles and manoeuvre tests with mopeds. In Iceland one  of the items of the theoretical training the first aid 
course, required together with a health statement.  

93   ES and LU do not allow persons to obtain A driving licence directly. 
94   CY and RO have newly introduced it and FI has retracted the obligation according to their responses. 
95   CY, FR and RO. 

31 

 
 
                                                           
Requirements for obtaining group category B driving licence 

The  directive  seems  to  have  brought  a  large  degree  of  harmonisation  but  not  total 
harmonisation of the requirements for obtaining group a category B driving licences. 

The general rule for categories B, C and D is that that applicants need to pass a test of skills and 
behaviour and a theoretical test and meet some medical standards, in accordance with Annexes 
II and III to the directive: 

Practical  testing  requirements  are  in  force  in  27  countries96.  Both  practical  and  theoretical 
testing  requirements  have  been  implemented  in  all  surveyed  countries  after  the  directive’s 
implementation.  Practical  training  is  implemented  in  22  Member  States. Health  examinations 
are an obligation in 20 of the surveyed Member States and one EEA country. 

Requirements for obtaining a group category C driving licence 

The  directive  seems  to  have  effected  a  high  degree  of  harmonisation  of  the  requirements  for 
obtaining group category C driving licences. 

Regarding national requirements for obtaining a C, C1, C1E and CE driving licence, after the 
implementation, all countries imposed a theoretical and practical test for citizens to obtain this 
type of driving licence.  

Since implementation, the total number of surveyed Member Sates imposing practical training 
increased to 19 with 2 additional Member State having implemented it97. Iceland and Norway 
also impose practical training. There are still several national specific requirements. 98 

Requirements for obtaining group category D driving licence 

The analysis points out to a high level of harmonisation of the requirements for obtaining group 
category D driving licence already existing prior to the directive’s implementation. 

Regarding the national requirements for obtaining a D, D1, D1E and DE licence, these have not 
changed significantly across countries before and after the implementation of the directive. As 
reported by the national authorities, even prior to the implementation, all countries except one 
had  imposed  theoretical  and  practical  test  requirements  for  citizens  to  obtain  this  type  of 
driving licence. Today all countries require both tests but additional national requirements are 
still in place99.  

96   It includes Norway and Iceland 
97   IE and RO 
98   BE indicated that the theory training is still optional while the practical training can be done with a learner's permit. SK  stated added the 
requirement of a psychological examination. In GR, no medical re-examination is needed, when the medical check is valid for Group 1 or 
2. In RO, an additional requirement is to hold a category B licence.  

99   For instance BG has highlighted special education requirements and in BE theoretical training is still optional. An additional requirement 
indicated by the German national authority is the certificate of conduct. In RO, an additional requirement is to hold a category B licence.  

32 

 
                                                           
During  the  interviews  with  national  authorities,  several  respondents  confirmed  that  training 
requirements vary among the Member States, however, they mostly stated that there is no need 
for  harmonisation  of  training  requirements  as  long  as  there  are  harmonised  standards  for 
driving examination.100  

Minimum standards for driving examiners 

The  analysis  indicates  that  Member  States  have  fully  implemented  the  new  minimum 
requirements  concerning  initial  qualifications  of  driving  examiners.  However,  there  are 
differences  across  the  countries  in  their  implementation.  The  analysis  also  highlighted  that 
Member  States  consider  that  the  current  quality  assurance  and  periodic  training  requirements 
are sufficient. 

Article 10 of and Annex IV to the third driving licence directive set out minimum standards for 
driving examiners concerning quality assurance and regular periodic training measures.  

According  to  the  implementation  study,101  all  Member  States  fully  implemented  the 
requirements concerning initial qualifications of driving examiners.  

Regarding the implementation of quality assurance requirements, 17 out of 20 Member States 
indicated full implementation102.  

The  targeted  survey  with  national  authorities  highlighted  some  variation  in  terms  of  the 
requirements for driving examiners. The majority of countries (25 out of 30) have implemented 
the supervision of examiners at work and periodic training and accreditation. Several countries 
(21 out of 30) have implemented periodic review of outcomes of driving tests.  
Member  States  consider  that  the  current  quality  assurance  and  periodic  training  requirements 
are sufficient.103 

Exchange of driving licences between Member States 

The directive seems to have effected a substantial degree of harmonisation of the exchange of 
driving  licences  in  application  of  the  principle  of  mutual  recognition,  despite  the  fact  that  in 
some  cases  the  exchange  has  to  go  through  an  administrative  verification  process  and  is  not 
always automatic.  

100   DE, DK, ES, FI, GR and SI and Norway, 
101   European Commission (2017), The implementation of Directive 2006/126/EC on driving licences. Report drafted by Hasselt University, 

NTUA. 

102   The implementation study found that the requirements on driving examiners have been implemented to varying degrees by the Member 
States. The requirements on initial qualification of driving examiners were fully implemented in all countries. The requirements on quality 
assurance were fully implemented in 17 out of 20 Member States and Norway indicated full implementation (AT, BG, DE, DK, ES, FI, 
FR,, IE, LV, LT, LU, NL, PL, SK, SE, Norway and United Kingdom). Out of the other three Member States, FR indicated that the quality 
component  was  not  put  in place until  May  2017,  which  is  why  the  requirements  were  being  partially  implemented;  SI  claimed  to  have 
differently implemented reaccreditation, but without indicating the way it is different; and PT claimed that these requirements were not yet 
all implemented, but they were in the national legislation. 

103   The implementation study found that the current level of requirements is considered sufficient by national authorities. For both quality 

assurance requirements and periodic training requirements, the implementation study found that 19 out of 20 Member States considered 
these to be sufficient. 

33 

 
                                                           
Article  2  of  the  directive  stipulates  that  driving  licences  issued  by  Member  States  shall  be 
mutually recognised. 

The implementation study104 and the targeted consultations show that only around one third of 
the  Member  States  automatically  recognise  driving  licences  issued  in  another  Member 
State/EEA country.  

A considerable share of the Member States (12 out 21) does not recognise licences in certain 
situations, e.g. when the minimum age is different than what it is allowed according to national 
requirements, or the proof of normal residence is not established.   

The  conditions  for  exchange  of  driving  licences  are  also  not  uniform.  For  instance  some 
countries only require a simple check of validity in RESPER, some require a formal proof of 
normal  residence,105  while  others  require  the  request  to  be  made  in  person  to  the  national 
driving licence authority. 

Exchange of driving licences between Member States following a prior recognition of a 
third country driver licence in another Member State 

The analysis seems to show, based on stakeholder views, that although Member States are not 
obliged to recognise the licences issued by  a third country  and  already recognised in  another 
Member State106, the majority recognise those driving licences. 

Article 11(6) of the directive gives Member States the possibility to exchange a driving licence 
issued by a third country for a Community model driving licence. Nevertheless, if the holder of 
this licence transfers his normal residence to another Member State, the latter  Member States 
need not apply the principle of mutual recognition set out in Article 2. The directive does not 
establish  a  uniform  framework  for  the  recognition  of  driving  licences,  leaving  the  possible 
recognition to be a matter for each Member State. 
The desk review107and stakeholder consultations show that 18 Members States recognise those 
driving licences automatically, while 8 require a conformity check. 

There are nevertheless differences in the conditions of those exchanges. For instance, some national 
authorities do not recognise third country licences if they do not have the prior existence of a mutual 
recognition agreement with that third country108,
the country109, while others only exchange it if the road safety conditions and requirements related to 

, some require a minimum residence of one year in 

104   European Commission (2017), The implementation of Directive 2006/126/EC on driving licences. Report drafted by Hasselt University, 

NTUA. 

105   FR. 
106   According  to  Article  11  (6)  of  the  directive  and  the  jurisprudence  of  the  ECJ-  Judgement  of  28  February  2019,  Case  C‑9/18; 

ECLI:EU:C:2019:148. Available at: http://curia.europa.eu/juris/document/document.jsf?text=&docid=211186&doclang=EN  

107   The European Commission (2017), The implementation study showed that 20 out of 25 of the Member States recognised licences issued 

following the exchange of a Driving licence issued by a third country, without any conditions. 

108   AT and IE. 
109   FR. 

34 

 
                                                           
a driving licence of the third country are comparable to the national ones110.Impact of differences 
in recognition of driving licences issued in third countries  

The  analysis,  is  based  mostly  on  Member  States  authorities  views  that  have  the  sole 
competence to recognise and exchange driving licences and seems to indicate that the lack of a 
uniform framework for the recognition of driving licences issued in third countries  may have 
led to an increased complexity and administrative burden for national authorities (too many and 
too diverse bilateral agreements and Memoranda of Understanding). However, the latter could 
not  be  quantified  during  the  data  collection  activities  and  lies  solely  on  a  qualitative 
assessment. 

In  the  survey  with  national  authorities,  two  national  authorities111  mentioned  that  the 
definitions  of  driving  licence  categories  in  third  countries  are  not  always  clear  and  that  the 
access to information from the third countries is difficult, thus rendering the recognition to be 
difficult112. Another obstacle for the recognition is that in many instances, third countries have 
less demanding standards of road safety when exchanging licences113.  

Nevertheless,  4  national  authorities’114  representatives  identified  no  challenges  related  to  the 
absence of a uniform framework for the recognition of driving licences. 

In the survey with non-governmental stakeholders, the highest share of respondents (16 out of 
41) have indicated that there were no challenges related to the absence of a uniform framework 
for  the  recognition  of  driving  licences  issued  by  third  countries,  while  approximately  one 
quarter indicated that  there  were  challenges  (10  out  of 41).  The  remaining  respondents  could 
not make an assessment. Non-governmental stakeholders also suggested that the provision has 
less impact on road safety than on free movement of citizens.  

One non-governmental stakeholder said that different rules regarding the recognition of driving 
licences  from  third  countries  represent  an  obstacle  for  third  country  nationals  to  moving  into 
the  EU,  since  their  driving  licence  -  once  exchanged  by  a  Member  State  -  might  not  be 
recognised  across  the  whole  EU.115  In  relation  to  the  professional  driver  shortage,  several 
interviewees  mentioned  that  the  lack  of  harmonisation  could  prevent  third  country  nationals 
from driving for EU hauliers, but that a driver shortage in the EU should not lead to loosened 
conditions and requirements for professional drivers coming from third countries.  

Another  non-governmental  stakeholder116  suggested  that  all  third  country  professional  drivers 
driving in the EU should have the same training and testing requirements as the EU nationals. 
The same respondent indicated that sometimes the certificates of professional competence117 are 
obtained too easily by third country professional drivers, and the requirements are less strictly 

110   DE. 
111   HR and NL. 
112   CY, FI, LV and Norway. 
113   ES, SE and SI. 
114   CZ, DE, LU and SK. 
115   UETR 
116   ETF 
117   In accordance with Directive 2003/59/EC 

35 

 
                                                           
applied  due  to  the  shortage  of  professional  drivers  in  the  EU.  Also,  the  non-EU  drivers  are 
more easily hired in certain Member States due to the low costs for drivers' attestation, which 
presents disadvantages for EU-national professional drivers compared to non-EU professional 
drivers. A non-governmental stakeholder118 suggested that there should be mandatory training 
and examination for all third-country nationals. 

During the interviews one national authority119 referred to the negative impact related to driving 
licence shopping that results from the lack of harmonisation of the requirements and stated that 
some  holders  of  a  third  country  driving  licence,  which  would  not  be  recognised  in  the 
Netherlands,  would  ‘shop’  for  a  more  favourable  Member  State  to  recognise  their  driving 
licence, and then use it in the Netherlands.  

5.1.2.3 
licence tourism” 

Objective  “Reducing  the  possibilities  of  driving  licence  fraud  and  driving 

Relevant questions to assess this objective: 

 EQ 2.3 To what extent have the possibilities of driving licence fraud and “driving license tourism” been reduced? 

EQ  2.2  In  which  areas  have  uniform  driving  licence  rules  and  requirements  been  established  across  MSs?  In 
which areas are there still divergences120 

The analysis seems to indicate, based on stakeholder views, that the new Community Model of 
driving  licence  may  have  improved  document  security  against  driving  licence  fraud  and  that 
driving licence tourism may have been reduced, but some challenges still remain including: the 
provision  on  normal  residence,  outdated  national  registers,  and  a  lack  of  harmonisation  in 
relation to the recognition of driving licences issued by third countries. However, there are no 
official  statistics  on driving licence  fraud  and driving licence tourism across  the EU Member 
States that allow for a quantitative assessment.  

Article 3 of the directive requires Member States to take necessary steps to avoid the forgery of 
driving licences, including that of the model driving licences issued before the entry into force 
of  the  directive.  Annex  I  to  the  directive  lays  down  a  series  of  provisions  concerning  the 
community model driving licence including security features to prevent the risk of forgery and 
fraud. 

Stakeholders  that  were  consulted  generally  agree  that  the  number  of  instances  of  driving 
licence fraud and driving licence tourism have been reduced due to the directive  

Overall national authorities had difficulties in providing an assessment of the extent to which 
the directives had contributed to decreases in the numbers of fraud compared to the period prior 
to  their  first  implementation.  Amongst  countries  that  made  an  assessment,  the  proportion  of 
national authorities that considered the directives to have made a contribution to the reduction 

118   BVF 
119   NL 
120   Insofar as the replies contained the data concerning anti-fraud measures.  

36 

 
 
 
                                                           
of  fraud  was  relatively  higher.  Specifically,  as  shown  the  (Table  4  in  Annex  V),  11  national 
authorities  found  that  the  directives  helped  decrease  the  number  of  forged  driving  licences 
detected per year, 10 national authorities assessed that the driving licence directive contributed 
to  reducing  driving  licence  fraud  involving  citizens  from  other  EU  countries  and,  finally,  6 
national  authorities  considered  the  driving  licence  directives  to  have  helped  reduce  fraud 
involving citizens of third countries as compared to 1983. In two Member States (BG and LU) 
different authorities within the same country had diverging opinions.  

The  feedback  from  the  targeted  consultation  seems  to  indicate  that  driving  licence  fraud  has 
been  reduced.  In  this  regard,  the  consulted  national  authorities  highlighted  the  importance  of 
RESPER to reduce fraud, since it facilitates an easier exchange of information and detects at an 
early stage whether a driving licence is not valid. 

However, the targeted survey with national authorities broadly confirmed that there may be a 
negative impact on road safety and driving licence tourism resulting from the absence of an EU 
framework for mutual recognition of driving disqualifications, but that this impact is difficult to 
assess121. 9 respondents suggested that the absence of an EU framework for mutual recognition 
of driving disqualifications has  a negative impact on road safety and driving licence tourism, 
and provided examples.122  

More than half of the surveyed non-governmental stakeholders (22 out of 41) perceived that the 
directive  has  led  to  lesser  instances  of  driving  licence  tourism  and  fraud,  around  20%  of  the 
respondents (8 out 41) claimed that opposite, and the remaining one quarter of the respondents 
(11 out 41) could not provide an assessment. 

In the open public consultation, opinions were split when it comes to the directive's role in the 
reduction  of  driving  licence  fraud  and  driving  licence  tourism.  Around  40%123  agreed  or 
strongly  agreed  that  the  directive  is  effective  in  this  regard,  whereas  40%124  disagreed  or 
strongly disagreed with this statement. 
Some  of  the  remaining  challenges  that  were  noted  by  stakeholders  include  the  fact  that  the 
implementation  of  counter-falsification  measures  varies  significantly  across  Europe.  In  the 
Stakeholders  workshop  it  was  stated  that  document  security  features  are  not  sufficiently 
adapted  to  evolving  counter-falsification  risks,  and  there  is  a  need  to  further  coordinate  the 
implementation of minimum data protection safeguards across Member States, as measures to 
protect against document fraud. 

The  implementation  study125  recommended  the  intensification  of  the  work  on  counter-
falsification  technologies  (including  false  identities),  given  that  more  and  more  cases  of 
lookalike attacks take place,  and it has been shown that the improved security features of the 
European driving licences provide an increased level of security for the document itself.  

121   AT, FR, IE, IT, LV, Norway, SI and SE. 
122   BE, BG, the NL, ES, SK, SI and Norway. 
123   217 out of 546 stakeholders 
124   223 out of 546 stakeholders 
125   European Commission (2017), The implementation of Directive 2006/126/EC on driving licences. Report drafted by Hasselt University, 

NTUA. 

37 

 
                                                           
Other remaining challenges noted by stakeholders included the lack of clarity of the provision 
on  normal  residence,  the  fact  that  some  national  registers  are  outdated,  and  the  lack  of 
harmonisation in relation to the recognition of driving licences issued by third countries. 
5.1.2.4 
drivers” 

Objective  “Raising  the  driving  skills  of  non-professional  and  professional 

Relevant questions to assess this objective: 

EQ 2.4 To what extent have the driving skills of non-professional and professional drivers been raised? 

EQ 4. To what extent the possible differences between Member States resulting from the lack of minimum and/or 
harmonised training obligations for learner drivers have had an impact on road safety?  

EQ 2.5 To what extent have the provisions on the qualification of driving examiners contributed to safe driving? Is 
the relevant monitoring framework fit for that purpose? 

The analysis indicates that the directive did not harmonise training requirements, although this  
was not one of its objectives, and there is limited evidence, based on stakeholder views, that the 
driving  skills  of  professional  and  non-professional  drivers  have  been  substantially  increased. 
The  only  exception  are  users  of  powered  two-wheelers,  where  the  introduction  of  graduated 
access  to  motorcycle  licences  seems  to  have  improved  the  driver  skills,  according  to 
stakeholder views. 

The directive, despite including minimum requirements for driver training and testing (Annex 
V  and  VI),  does  not  introduce  harmonised  training  obligations  and  there  is  a  wide  variety  of 
approaches  in  terms  of  training  requirements  across  Member  States126
.  The  evaluation  has 
attempted  to  determine  if  this  non-harmonised  approach  has  raised  the  driving  skills  of  non-
professional and professional drivers. 

A  large  proportion  of  the  surveyed  national  authorities  couldn’t  provide  any  assessment  on 
these matters127. Nevertheless,  several  national  authorities indicated during the interviews that 
the  driving  skills  of  non-professional  and  professional  drivers  have  not  been  significantly 
raised.  

The survey with non-governmental stakeholders indicates that drivers have now better driving 
skills and improved behaviour, but that it was difficult to determine whether the results could 
be  attributed  to  the  directive,  since  several  Member  State  already  had  very  high  standards  in 
terms of education and testing before the implementation of the directive. 

In  the  targeted  survey  with  non-governmental  organisations,  more  than  half  of  the  41 
stakeholders  considered  that  the  directive  led  to  improved  driving  skills  of  professional  and 
non-professional drivers. Around 20% (8 out of 41) perceived that the directive has not led to 
improved  driving  skills  of  professional  drivers,  and  slightly  more  respondents  (11  out  of  41) 
indicated that the driving skills of non-professional drivers have not been improved as a result 

126   According to the results of desk review and the survey analysis. 
127   52% of the 32 national authorities could not make an assessment for professional drivers, respectively 46% could not make an assessment 

for non-professional drivers. 

38 

 
  
                                                           
of the directive. The results from the interview analysis showed that there was only a limited 
increase in the driving skills of non-professional and professional drivers.  

In  the  open  public  consultation,  56%  of  the  stakeholders128  considered  that  drivers  who  had 
succeeded in the examination were better qualified than before.  

To what extent  have  the possible differences  between Member States  resulting from the 
lack  of  minimum  and/or  harmonised  training  obligations  for  learner  drivers  had  an 
impact on road safety? 

The results of the analysis are mixed on this point. Most of the authorities were of the opinion 
that  the  lack  of  minimum  and/or  harmonised  training  obligations  has  had  no  impact  on  road 
safety. On the other hand, non-governmental stakeholders consider that training  requirements 
should be further harmonised across the EU. 

The directive, despite including minimum requirements for driver training and testing (Annex 
V  and  VI),  does  not  introduce  harmonised  training  obligations  and  there  is  a  wide  variety  of 
approaches in terms of training requirements across Member States129. The literature assessing 
the effects of an absence of a harmonised framework for training requirements in  the driving 
licence directive is rather scarce, therefore the conclusions mostly rely on the results provided 
during the stakeholder consultations. 

The  survey  of  national  authorities  provided  mixed  views.  11  out  of  29  Member  States 
considered that there are no challenges in terms of road safety with the current harmonisation 
of  practical  training  requirements,  and  11  respondents  could  not  assess  the  matter.  The 
remaining  7  surveyed  national  authorities  believed  that  there  are  some  challenges  resulting 
from the current level of harmonisation.  

During  the  interviews  with  national  authorities,  none  of  the  national  authorities  explicitly 
assessed that the discrepancies in training obligations for learner drivers across Member States 
affected road safety in the EU in any way.  

As  regards  theoretical  training,  12  out  29  governmental  authorities  consider  that  there  are  no 
specific challenges, while 11 remained undecided. 6 surveyed national authorities believed that 
there  are  some  challenges  resulting  from  the  current  level  of  harmonisation.  Only  one 
respondent explicitly suggested that the challenges relate to road safety. Several indicated that 
no  further  harmonisation  is  needed  since  the  directive  stipulates  minimum  requirements  for 
driving examinations, which are sufficient.  

In the interviews with non-governmental organisations, the respondents listed several negative 
consequences  for  road  safety  arising  from  the  lack  of  harmonisation.  For  example,  some 
indicated that the Member States do not focus enough on training requirements130, that they do 

128   i.e. 305 out of 546 respondents. 
129   According to the results of desk review and the survey analysis. 
130   STR, FEMA, ETSC. 

39 

 
                                                           
not  require  lifelong  learning,131  and  that  are  no  training  obligations  for  motorcycles  in  the 
directive.132  

Effect of the directive on the qualifications of driving examiners 

The analysis suggests that the harmonised rules on driving examiners had a positive impact on 
road safety and that the current level of harmonisation is broadly sufficient.  

The  directive  (in  article  10)  has  harmonised  the  initial  qualification  and  periodic  training  of 
driving examiners requiring that they meet minimum standards for their work, including quality 
assurance and regular periodic training. 

The responses to the survey with non-governmental stakeholders133 indicated that the minimum 
standards  for  driving  examiners  are  one  of  the  most  important  provisions  for  improving  road 
safety. This  finding is  also supported by the results  of the targeted survey  and the interviews 
with national authorities. 

Desk research134 reveals that Member States considered that the level of requirements for both 
quality  assurance  and  periodic  training  as  of  2017  to  be  broadly  sufficient  (19  out  of  20 
Member States). In that study, stakeholders also indicated that periodical training should focus 
on quality rather than intensity.  

 Although  being  broadly  sufficient  both  the  desk  research135  and  the  targeted  surveys  with 
national  authorities  and  non-governmental  stakeholders  point  out  that  the  qualifications  of 
driving examiners should be updated with new skills such as: 

  knowledge on examination design, test execution and training 

  psychological knowledge and better communication skills136 

  knowledge  on  new  technologies,  advanced  driver  assistance  and  energy  efficiency 

increasing systems and semi-autonomous driving 

  continuous training on lighter categories of vehicles. 

131   STR, FIA. 
132   FEMA and European Transport Safety Council. 
133   5 automotive and motorcycle federations, 2 drivers associations, 7 drivers school associations, 1 international road transport associations, 

10 road safety and road users associations, 2 vehicle manufacturer associations, 7 'other category' 

134   European Commission (2017), The implementation of  Directive 2006/126/EC on driving licences. Report drafted by Hasselt University, 

NTUA. 

135   European Commission (2017), The implementation of  Directive 2006/126/EC on driving licences. Report drafted by Hasselt University, 

NTUA. 

136   The  implementation  of  Directive  2006/126/EC  on  driving  licences.(drafted  by  Hasselt  University,  NTUA)  noted  that  the  lack  of 
communication  skills  seem  to  be  the  examiners’  weakest  point  and  that  these  skills  are  some  of  the  most  demanding  and  difficult  to 
improve. Issues like examination anxiety are considered important and driving examiners should be able to deal with it. That  study also 
noted that Member States should foresee that theory tests and practical tests for driving instructors should include testing of knowledge on 
educational methods and the skills to apply these methods. The ability to observe the candidate should be taught during the basic practical 
training. European Commission (2017); 

40 

 
 
 
                                                           
5.1.2.5  
rules” 

Objective  “Facilitate  implementation  and  enforcement  of  driving  licence 

Relevant questions to assess this objective 

EQ 2.7 To what extent has the application and the enforcement of driving licence rules by Member States been 
facilitated? 
EQ 3 To what extent has RESPER facilitated the objectives of the directive and what are its shortcomings, if 
any? 
EQ 6 What has been the impact, if any, of the absence of an EU framework for the mutual recognition of 
driving disqualifications on road safety in general and on driving license tourism in particular? 
EQ 9 Has the directive resulted in any excessive costs / negative impacts? 

To what extent has the enforcement of driving licence rules by Member States been 
facilitated? 

The  analysis  seems  to  indicate  that  the  enforcement  of  driving  licence  rules  was  somewhat 
facilitated by the directive, although it is difficult to draw definite conclusions solely based on 
stakeholder views. The qualitative findings from desk research, targeted surveys and interviews 
are mixed, and there are no official statistics on enforcement across the EU Member States. 

Article  15  of  the  directive  states  that  Member  States  should  assist  each  other  in  the 
implementation  of  the  directive  and  exchange  information  on  the  licences  they  have  issued, 
exchanged,  replaced,  renewed  or  revoked.  RESPER  is  the  network  that  operationalises  the 
information exchange between driving licence authorities in the Member States.  

All Member States are obliged to connect to and use the RESPER network. The main objective 
of the platform is to ensure the 'one person, one licence' principle, which ensures that drivers 
are qualified for driving and to verify possible instances of driving licence fraud by verifying 
the validity of licences issued by other countries. 

In  the  targeted  survey  with  national  authorities, findings  were  mixed;  14  national  authorities 
considered  that  the  directive  facilitated  the  enforcement  of  driving  licence  rules,  referring  in 
particular the provisions on the harmonised driving licence model, the RESPER  network and 
the Commission's decision on equivalences as factors leading to enforcement and reduction in 
fraud  instances.137  Nevertheless,  4  national  authorities138  stated  that  the  directive  has  not 
facilitated the enforcement of driving licence rules, and 13 national authorities could not make 
an assessment.139  

During  interviews,  5  out  of  8  interviewed  national  authorities  indicated  that  the  enforcement 
has  been  facilitated  to  a  high  extent,140  and  the  other  three  interviewees  gave  a  slightly  less 
positive assessment. 

137   BE, BG, CY, CZ, EE, FI, DE, IE, LV, LU, MT, PL, SI, and ES. 
138   BG, FR, IT and NL. 
139   AT, DK, GR, HU, HR, LU, LT, PT, RO, SE, SK, Iceland and Norway. 
140   DE, DK, ES, GR and SI. 

41 

 
                                                           
All  eight  interviewed  national  authorities  considered  that  the  main  factors  that  contributed  to 
the  facilitation  of  the  application  and  the  enforcement  of  driving  licence  rules  were  the 
harmonisation of requirements, the uniform driving licence model and RESPER.  

Non-governmental  stakeholders  replying  agreed  that  the  directive  somewhat  facilitated  the 
enforcement of driving licence rules. 

Effectiveness and shortcomings of RESPER in facilitating the objectives of the directive  

The analysis seems to suggest, based on stakeholder views, that overall RESPER is an effective 
tool  for  the  exchange  of  information  between  national  authorities  and  has  contributed  to 
facilitating free movement. 

The advantages of RESPER identified by stakeholders are: the fast exchange of driving licence 
information;  access  to  relevant  information  on  validity  of  driving  licences;  possibility  to 
prevent driving licence fraud and accelerate the procedures related to the exchange and renewal 
of driving licences; and facilitation of the implementation of the principle of mutual recognition 
of driving licences. The evidence is less conclusive on whether RESPER helped reducing the 
administrative burden by reducing processing times for driving licences. 

The disadvantages relate both to the system's quality (query errors, incomplete information) as 
well  as  limited  uses  (RESPER  is  not  being  utilised  when  it  comes  to  exchange  of  driving 
information for enforcement purposes, exchange of information on demerit points, exchange of 
information on national codes, and normal residence).  

The  implementation  study141  found  that  RESPER  had  contributed  to  the  free  movement  of 
persons  through  the  simplification  of  administrative  procedures,  which  allowed  for  quicker 
exchange  and  replacement  of  driving  licences.  It  also  found  that  RESPER  had  facilitated  the 
implementation  of  the  'one  person,  one  driving  licence'  principle  as  a  result  of  the  swift  and 
simultaneous  checks  of  the  driving  licence  information  which  enables  the  detection  of  cases 
where one person has more than one driving licence in different countries. RESPER has also 
helped to fight against fraud in the instance of exchange requests of driving licence for vehicle 
categories for which drivers are not  qualified and/or authorised in a  Member state other than 
the one of their normal residence. In terms of reduction in the administrative burden, the study 
was less conclusive. Only half of the Member States considered that RESPER had reduced the 
administrative  burden  in  the  exchanges  and  renewals  of  driving  licences.  In  the  case  of  first 
issuance  of  driving  licences,  approximately  one  third  of  the  Member  States  considered 
RESPER to have had no effect.  

In the evaluation’s survey with the national authorities, 22 out of 28 authorities indicated that 
RESPER  helped  identifying  licence  fraud  and  driving  licence  tourism.  The  majority  of  the 
authorities found that processing times had remained the same after the implementation of the 
directive. 

141   European Commission (2017), The implementation of  Directive 2006/126/EC on driving licences. Report drafted  by Hasselt University, 

NTUA. 

42 

 
                                                           
Advantages of RESPER 142: 

  Fast exchange of driving licence information (according to 15 out of 22 national authorities) 

  Access to relevant information on validity of driving licences143  

  Possibility to prevent driving licence fraud and accelerate the procedures related to exchange 
and renewal of driving licences144; the principle of mutual recognition of driving licences145 

  Reduction fraud146 

  Using the information for enforcement purposes147 

  Using the information in the process of exchanging driving licences148 

Disadvantages of RESPER  

 

 

Information  made  available  should  be  more  accurate  and  comprehensive  system  regarding 
withdrawn driving licences)149 

In the case of exchange of driving licences, Code 70150 is not always displayed even if it is 
imprinted on the driving licences151 

  Different interpretation of driving licence status across countries152 

  Not all Member States systematically make use of RESPER153 

  Lack of user-friendliness 154  

  Limitations in terms of the connection of RESPER to other systems such as TACHOnet155  

142   According to the findings of the survey and interviews with national authorities. 
143   DK, HR NL, LT and LU. 
144   BE, DE, CY, GR, RO, and ES. 
145   ES. 
146   BE and ES. 
147   BE, SI, FI, and BG  
148   NL, SI and ES.  
149   BE, BG, CZ, FI, GR, DE, HU, LV, RO, SK, SI, SE, IE, ES and Norway. 
150   According to Article 11(6) of the directive “Where a Member State exchanges a driving licence issued by a third country for a Community 
model driving licence, such exchange shall be recorded [with a code 70 according to point 3 of Annex I to the directive] on the Community 
model driving licence as shall any subsequent renewal or replacement. Such an exchange may occur only if the licence issued by the third 
country has been surrendered to the competent authorities of the Member State making the exchange. If the holder of this licence transfers 
his normal residence to another Member State, the latter need not apply the principle of mutual recognition set out in Article 2.” 

151   BE, DE, DK, IE, LU, SI and SK. 
152   Norway.  
153   DK, GR, LT and RO. 
154   BE and IE. 
155 TACHOnet is a telematic network in operation across the EU  and beyond (non-EU AETR countries) to allow  an automated exchange of 

driver card information between member countries and thus fight against fraud...  

43 

 
 
 
                                                           
What has been the impact, if any, of the absence of an EU framework for the mutual 
recognition of driving disqualifications on road safety in general and on driving license 
tourism in particular? 

The evaluation indicates that the absence of a common framework for mutual recognition 
of driving disqualifications poses challenges when it comes to preventing abuse by drivers 
that  commit  offences  on  the  territory  of  one  Member  State  but  then  can  drive  in  another 
Member State with impunity for those offences. 

The problem was raised also at the level of the Court of Justice of the European Union, which 
has shown several challenges when it comes to the recognition of the cross-border effects of a 
decision on the withdrawal of the right to drive in another Member State, in particular when the 
decision  is  taken  in  the  country  of  first  issuance  and  there  is  a  request  for  exchange  of  the 
driving licence in the new country of residence. 

In  the  absence  of  a  clear  EU  framework,  the  Court  of  Justice  of  the  European  Union  issued 
several  clarifying  rulings  on  the  subject156.  For  instance,  in  the  recent  Case  C‑112/19  –  Kreis 
Heisenberg157  the  Court  ruled  that  the  second  subparagraph  of  Article  11(4)  of  the  directive 
must be interpreted as meaning that, in  the case of a withdrawal  of the authorisation  to  drive 
from  the holder of a driving licence in  a Member State, prior to  the exchange of that driving 
licence in another Member State in accordance with Article 11(1) of the directive, the former 
may still refuse to recognise the driving licence which was the subject of the exchange. 

The targeted survey with national authorities broadly confirmed that there is a negative impact 
on road safety and driving licence tourism resulting from the absence of an EU framework for 
mutual  recognition  of  driving  disqualifications,  and  that  this  impact  is  difficult  to  assess158  9 
respondents suggested that the absence of an EU framework for mutual recognition of driving 
disqualifications has a negative impact on road safety and driving licence tourism, and provided 
examples.159  

The  negative  impact  on  road  safety  and  driving  licence  tourism  was  suggested  also  by 
participants in interviews with national authorities and non-governmental stakeholders.160 One 
national authority161 stressed the problem of non-harmonised procedures in the case of driving 
bans imposed on non-residents. 

In  interviews,  three  non-governmental  stakeholders162  indicated  that  a  better  exchange  of 
information on driving offences is needed, for instance, by establishing an EU-wide database. 
This  would  be  especially  useful  for  professional  drivers,  and  a  good  example  is  the  bilateral 

156   Judgement of 21 May 2015, Case C‑339/14; ECLI:EU:C:2015:333 
156   Judgement of 26 April 2012, Case C 419/10 ECLI:EU:C:2012:240. 
157   Judgement of 4 February 2019, Case C‑112/19, ECLI:EU:C:2020:864. 
158   AT, FR, IE, IT, LV, Norway, SI and SE. 
159   BE, BG, the NL, ES, SK, SI and Norway. 
160   National authorities representing GR, the NL, SI, DE, BG, ES and individuals representing non-governmental organisations FIA, IFMC, 

ACEM, CIECA, ETF, UETR and BVF. 

161   DE 
162   ETF, UETR and BVF. 

44 

 
 
                                                           
agreement  between  the  Netherlands  and  Germany,  whereby  the  system  of  demerit  points/ 
disqualification system is harmonised for truck drivers from both countries163.  

Several other respondents explicitly suggested that some kind of a harmonised approach at EU 
level  would  be  welcomed164.  Nevertheless,  national  authorities  consider  harmonisation  a 
complex task with implications on other legislation such as on driving rules, alcohol in traffic, 
demerit points and criminal law rules, which are not aligned across the Member States. 

It is worth noting that at the High-Level Group on road safety on 5 October 2017 in Brussels, 
the majority of the Member States considered that driving disqualifications should be mutually 
recognised and there was a preference for an EU-wide approach165.  

5.1.2.6 

Objective “Protect novice drivers” 

Relevant questions to assess this objective 

EQ 2.6 To what extent have novice and/or young motorcycle drivers been protected? 

EQ 7 Which factors have contributed to/hindered the achievement of objectives? 

The  analysis  seems  to  point  to  an  improvement  of  the  road  safety  of  novice  drivers,  novice 
motorcyclists and novice moped riders, as a result of the directive. However, this conclusion is 
mostly based on data analysis, while stakeholder views are more divergent as to the impact of 
the directive on these user groups. 

The directive (article 4) has introduced a new category of driving licences for Mopeds and has 
limited  the  direct  access  to  category  A  driving  licences  (the  licences  for  driving  the  most 
powerfully motorcycles) for motorcyclists younger than 24 years old. They may have access to 
that  category  before  being  24  years  old  only  if  they  have  held  a  licence  in  a  lower  category 
(category A2) for at least two years. 

Previous literature, as well as the interviews and surveys conducted as part of the support study 
point to inconclusive findings in relation to the effect of the directive on road safety for these 
categories  of  road  users  (although  overall  assessment  of  stakeholders  tends  to  be  positive). 
Nonetheless,  the  evidence  provided  in  previous  studies  and  by  stakeholders  during 
consultations was of a qualitative nature and was not substantiated by data beyond perceptions 
of stakeholders. While acknowledging the diverging stakeholders’ perceptions, on the basis of 
the  statistical  modelling  conducted,  it  can  be  concluded  that  objective  quantitative  evidence 
points  to  a  positive  effect  of  the  directive  in  terms  of  improving  road  safety  for  young  and 
novice riders. 

The results of several statistical analyses that were developed indicate that, when the directive 
was fully in place, it had a positive effect on road fatalities. 

163   BVF 
164   BG, CY, DE, ES and GR. 
165   A non-paper was presented on the mutual recognition of driving disqualifications at the High Level Group on Road Safety 5 October 2017, 

Brussels. 

45 

 
 
 
                                                           
For powered Ttwo-wheeler (PTW) users (motorcyclists and moped riders), the reduction of the 
fatality trends for the novice PTWs are greater compared to the middle-aged groups which were 
not targeted with specific measures by the  directive , indicating a positive effect of the Third 
driving licence directive on road safety for the novice road users. 

The results of the  data analysis on PTW fatalities show that the  third  and the  second  driving 
licence  directive  had  caused  a  reduction  of  8%  in  the  PTWs  fatalities  per  population  in  EU 
countries. 

For  drivers  aged  18-24,  the  reduction  of  fatality  rates  was  4.9%  per  year,  whereas  for  the 
middle-aged drivers (aged 25-64, who are not directly affected by the directive) fatality figures 
may have decreased by 0.6% per year for the 25-49 age category, and increased by 1.7% per 
year for the 50-64 age group respectively.  

Finally, the results of the analysis of Novice Drivers Fatalities show that presence of the third 
driving  licence  directive  fully  implemented  may  have  caused  a  reduction  of  21.3%  on  the 
novice driver fatalities per population in EU countries. 

The  implementation  study166  pointed  to  the  fact  that  the  new  system  for  category  A  has 
improved road safety and driver education, namely by preventing young people from riding at 
an age where they are more prone to risky behaviour. Another benefit is that motorcycle riders 
continue  using  less  powerful  bikes  for  a  longer  period,  as  evidenced  by  the  increase  in  A2 
vehicles in the market. 

According  to  the  implementation  study  on  driver  training,  testing  and  medical  fitness167,  age 
and inexperience play a key role in explaining the number of casualties for this road user group. 
Some literature review suggests that formal instruction may not always have a direct effect on 
safety. Some authors168 note that, although in theory professional driving instruction improves 
driving  skills,  these  skills  do  not  always  transfer  to  the  real  world  when  young  drivers  drive 
without supervision. 

The literature review also indicates that the progressive access to a category A driving licence 
is perceived positively in terms of road safety by national authorities. It must also be noted that 
in the answers to EQ7169 stakeholders have indicated that the provisions on the introduction of 
minimum  age  limits,  minimum  testing  requirements  and  graduated  access  system  for 
motorcycle licences where key developments for road safety. 

The interviews have shown that it is difficult to assess whether the  directive has led to better 
protection of young and novice riders, but in general it was suggested that progressive schemes 
are  beneficial.  In  the  targeted  surveys,  only  8  out  of  32  national  authorities  considered  the 
directive to have had a positive effect on novice and young drivers in terms of road safety. Non-

166   European Commission (2017), The implementation of  Directive 2006/126/EC on driving licences. Report drafted by Hasselt University, 

NTUA. 

167   European Commission (2017), Study on driver training, testing and medical fitness. Report drafted by TRL, SWOV, BASt, Loughborough 

University, Monash University. 

Groeger,  J.  A.,  &  Banks,  A.  P.  (2007).  Anticipating  the  content  and  circumstances  of  skill  transfer:  unrealistic  expectations  of  driver 
training and graduated licensing? Ergonomics, 50(8), p. 1250-1263. 
169   Which factors have contributed to/hindered the achievement of objectives? 

46 

 
                                                           
governmental stakeholders have a different opinion (20 out of 41 responded that the directive 
improved road safety for young and novice drivers).  
In the Interviews with national authorities, 5 out of 8 interviewees indicated that novice and/or 
young motorcycle drivers are sufficiently protected170. 

In  the  Open  Public  Consultation,  54%  (302)  of  respondents  found  that  the  graduated  access 
system  for  motorcycle  licences  had  very  little  impact  on,  or  did  not  at  all  lead  to,  an 
improvement in road safety171.  

In the interviews with non-governmental authorities, 4172 out of 8 interviewees highlighted that 
young and motorcycle riders are sufficiently protected under the directive.  

5.1.2.7 

Factors that contributed to or hindered the achievement of objectives  

EQ 7: Which factors have contributed to/hindered the achievement of objectives?  

The analysis found that several factors may have had a positive contribution to the two general 
objectives  of  the  directive,  improving  road  safety  and  free  movement.  They  include  the 
achievement of both the specific objectives of protecting young drivers and improving skills of 
professional  and  non-professional  drivers,  as  well  as  the  achievement  of  the  operational 
objectives,  which  include  the  harmonisation  of  minimum  standards  for  driving  examiners 
(including quality assurance and regular periodic training), minimum testing requirements for 
drivers,  medical  examinations  for  professional  drivers,  minimum  age  per  categories,  and 
progressive access to a category A licence.  

On  the  other  hand,  the  achievement  of  the  objective  of  road  safety  is  likely  to  have  been 
hindered by the absence of EU measures for the  mutual recognition of driver disqualifications. 

Concerning the achievement of the general objective of improved free movement of citizens, it 
has been positively affected by the harmonisation of the EU driving licence rules, particularly 
mutual  recognition,  harmonisation  of  driving  licence  categories  and  vehicles’  definitions,  the 
Community  Model  driving  licence,  RESPER  and  minimum  age  limits  per  category.  On  the 
other  hand,  the  achievement  of  the  objective  has  been  hindered  by  the  definition  of  normal 
residence, the absence of a framework for mutual recognition of driving licences issued in third 
countries, and the continued use of old national driving licence models (until 2033). 

Positive and negative unexpected effects of the directive  

EQ 8: Has the directive led to any positive or negative unexpected effects?  

170   BE, DE DK, GR and SI. 
171   A large proportion of the respondents that expressed a negative view concerning the effectiveness of graduated access originated from the 
NL (227 respondents) The respondents from the NL emphasised that particularly category A1 motorcycles have insufficient power which 
could have implications in terms of road safety when it comes to driving on highways. 

172   STR, FIA, ACEM and BVF. 

47 

 
 
 
                                                           
The two main unexpected effects of the directive seem to be: driving licence tourism as a result 
of  lack  of  operability  of  the  provision  on  normal  residence;  and  an  increased  number  of 
unlicensed  motorbike  riders  due  the  cost  and  complexity  of  the  progressive  access  system  to 
category A driving licences. 

During the interviews, four national authorities173 indicated that the rules regarding the normal 
residence and driving licence tourism are the cause of a major negative unexpected effect.  

In the targeted survey with national authorities, when asked whether there are any challenges 
related to  the definition of normal  residence, the majority of the respondents  (22 respondents 
representing  20  countries)  agreed  that  there  are  some  challenges  related  to  the  definition  of 
normal  residence and the 185-days rule foreseen in  the  directive.174 The challenges reported 
by  the  authorities  come  from  the  difficulty  in  applying  the  definition  of  normal  residence  to 
certain types of residents and situations, particularly for:  

  Students, pensioners or other persons that have short term stays on the territory of another 
Member  State175  or  persons  whose  driving  licence  needs  to  be  renewed  after  moving  to 
another Member State 176 

  EU citizens who have their normal residence outside the  European Economic Area (e.g. 

Danish citizens who have their residence in Greenland)177 

   Persons who emigrate from third countries178  

  Persons whose driving licence has been lost, expired or stolen179 

  Persons  with  a  secondary  house  or  who  spend  185  days  on  the  territory  of  another 

Member State in a manner fractioned over time 180 

  Persons who meet the conditions of normal residence in more than one Member State at 

the same time181  

  Where the definition of normal residency has been legally challenged by applicants within 

an international protection process or illegal residents182  

  Difficulties in checking and establishing normal residence (e.g. difficult to determine the 
start of the 185 days period as residents are not required to register when they enter the 
country183 and to calculate the 185 'per calendar year184) 

173   BE, NL, GR and BG 
174   AT, BG, BE, CY, DK, FI, DE, GR, IT, IE, LV, LU, LT, NL, RO, SK, SI, ES, SE and Norway. 
175   CY, DK, FI, DE and LV. 
176   BE. 
177   DK and Norway. 
178   SE 
179   BE and LU 
180   AT and LU 
181   BE 
182   IE 
183   CY, DK, FI, DE and RO 
184   GR 

48 

 
                                                           
  Lack of clarity on how personal and occupational ties can be proven185  

  Lack of a harmonised method for proof of normal residence186 

However,  in  the  targeted  survey  with  national  authorities,  5  mentioned  that  there  are  no 
challenges with the definition of normal residence and the 185-days rule187 and the remaining 
respondents did not know or were not able to provide an assessment188. 
Secondly, the findings from the desk research pointed to an increased number of unlicensed 
novice drivers in some countries as a result of the introduction of the category AM for mopeds 
and the graduated access system for motorcycles.  

According to the existing studies, the number of unlicensed riders involved in traffic accidents 
in  some  countries  has  increased.  For  example,  a  Norwegian  study189  that  analysed  all  of  the 
fatal  accidents  involving  motorcycles  from  2005  to  2009  found  out  that  driving  without  a 
licence accounted for approximately 20% of the fatal accidents. Those studies pointed out that 
unlicensed drivers had not been trained and had not passed a driving test; therefore, they lacked 
the necessary skills and their driving was often associated with extreme behaviour. More than 
one  third  of  all  accidents  triggered  by  extreme  behaviour  involved  unlicensed  drivers. 
Similarly,  a  Swedish  study190  concluded  that  the  proportion  of  riders  without  a  licence 
accounted  for  25%  of  all  fatal  motorcycle  accidents  from  2005  to  2010.  The  study  also 
concluded that new requirements in relation to the A category driving licence have not led to 
reduced  accident  rates.  On  the  contrary,  the  proportion  of  killed  riders  that  did  not  possess  a 
valid licence increased every year.  

A number of consulted stakeholders suggested that the graduated access to motorcycle driving 
licences is perceived to be more complex and costly for novice riders.  

Apart  from  the  two  Scandinavian  studies  mentioned  above  and  based  on  the  answers  in  the 
survey  with  non-governmental  stakeholders,  it  is  impossible  to  assess  whether  the  number  of 
unlicensed  (and  untrained)  motorcycle  riders  has  increased  over  time.  While  17  out  of  38 
survey participants were unable to provide an assessment in this regard, 11 (29%) participants 
considered the number of unlicensed and untrained motorcycle riders to have decreased, while 
10 respondents (26%) indicated that the number of unlicensed and untrained motorcycle riders 
have not been reduced. On the other hand, a vast majority of the respondents in the survey with 
national authorities (29 out of 32) indicated that the directive did not have any effect on road 
safety for unlicensed drivers (the number of road fatalities and serious injuries at national level 
for this category of drivers). Only two authorities provided positive assessments in this regard 
and one national authority indicated a negative impact on road safety for unlicensed drivers. 

185   LT and NL  
186   SI and SK  
187   CZ, HR, EE, HU and PL 
188   FR and Iceland  
189   Statens  vegvesen  (Norwegian  Public  Roads  Administration),  2011:  Special  Analysis.  Fatal  Motorcycle  Accidents  2005-2009  
(the  Norwegian  Motorcycle  Union)  NMCU:  

(report 
https://nmcu.org/wp-content/uploads/2016/12/Analysis-fatal-motorcycle-accidents-2005-2009.pdf) 

of  Norsk  Motorcykkel  Union 

the  website 

found 

on 

190   Sveriges Motorcyclister (Swedish Motorcyclists), 2015: Extreme Behaviour – Mainly a Question of Driving without a Licence, version 2.0 

https://www.svmc.se/smc_filer/SMC%20centralt/Rapporter/2016/Extreme_behaviour_V2_0_2016.pdf 

49 

 
                                                           
In  the  Open  Public  Consultation,  54%  (302)  of  respondents  found  that  graduated  access  led 
very slightly or did not lead at all to improving road safety. Nevertheless, a large proportion of 
the  respondents  that  expressed  a  negative  view  concerning  the  effectiveness  of  graduated 
access  originated  from  the  Netherlands  (227  respondents).  The  respondents  from  the 
Netherlands  emphasised  that  in  particular,  category  A1  motorcycles  have  insufficient  power 
which could have implications in terms of road safety when it comes to driving on highways. 

The  interviewees  indicated  several  other  aspects  where  the  directive  generated  unexpected 
effects.  Specifically,  these  related  to  the  postponement  of  training  and  testing  by  motorcycle 
riders, discrimination against below-average size riders at examination, and a limited incentive 
for  young  motorhome  drivers  to  obtain  category  C  driving  licence  due  to  high  costs.  These 
aspects were generally perceived as being negative effects by the stakeholders consulted. 

50 

 
 
 
5.2 

Efficiency 

The  directive  introduced  several  novelties  that  could  be  associated  with  costs  and  extra 
administrative  burden  for  citizens,  including:  the  introduction  of  the  new  EU  driving  licence 
model;  the  introduction  of  progressive  access  to  category  A  licences;  and  the  introduction  of 
harmonised  administrative  validity  periods  for  driving  licences.  Therefore,  in  this  subsection 
we assess the actual costs and their possible variation compared to the benefits the directive has 
generated.  Any  potential  for  simplification  and  reduction  of  unnecessary  regulatory  costs  is 
also identified. 

Possible existence any excessive costs / negative impacts  

EQ 9: Has the directive resulted in any excessive costs / negative impacts? 

Costs and administrative burden for citizens  

The analysis indicates, based on stakeholder views, that the introduction of a common  Union 
model  for  driving  licences  did  not  lead  to  major  changes  in  the  costs  incurred  by  citizens  to 
obtain  a  driving  licence,  as  compared  to  the  situation  prior  to  the  directive.  However,  it  is 
difficult to establish a baseline cost without any directive in place and thus assess the impact of 
the directive itself. There is very little data to quantify any costs related to the directive. 

The  introduction  of  the  new  Union  licence  model  was  one  of  the  changes  introduced  by  the 
directive,  and  was  introduced  by  Article  1  of  the  directive.  The  new  Union  licence  model, 
based on an ISO standard, has been adopted by many Member States after the adoption of the 
directive, and even before its entry into force191.  

The new Union licence model did not bring about significant changes in the organisation of the 
licensing  system.  While  most  European  citizens  must  visit  a  public  administration  office  to 
apply for a driving licence, some Member States offer this service on a web platform.  

The  implementation  study  showed  that  the  cost  for  obtaining  a  driving  licence  was  not 
substantially  affected  by  the  implementation  of  the  Union  licence  model192.  Small  increases 
were  nevertheless  found  in  eight  Member  States  and  in  one  EEA  country193.  The  increase  in 
fees could be reasonably traced to the production cost of the credit card licence in two countries 
(Norway and Poland). The other changes could not be explained by the study. By contrast, in a 
few Member States the fees for the issuance of a driving licence actually dropped194.  

Thus, overall, the data points to some increase in the costs associated with obtaining a driving 
licence, but these changes are not consistent across Member States.  

191   AT, BG, CZ, EE, FI, DE, HU, IT, LV, LT, MT, NL, PL, PT, SK, SI, ES, SE. Iceland also adopted the Union Model. 
192   Only the costs associated with the administrative process and the document, and no other costs such as driving school costs, test fees or 

costs for medical checks and first aid courses. 

193   The increase amounted to between a few eurocents and approximately EUR 25. Increases in fees were noted in BE, HR, GR, IE, LT, PL, 

MT, SI, and in Norway. 

194   CY and FI. 

51 

 
                                                           
In the targeted interviews, 12 out of 20 national authorities195 indicated that there had not been 
any notable changes in fees and, where they had occurred, they were related to yearly updates 
of fees and normal indexation. The assessment of the authorities in the interviews was similar 
when it came to the processing time for issuing, exchanging, replacing, and renewing driving 
licences, i.e. the time needed remained broadly the same.  

The survey of non-governmental stakeholders showed a mixed picture in terms of the overall 
assessment of whether the procedures regarding first issue, renewal, exchange, and replacement 
of professional and non-professional licences have become less costly and complex.  

The  implementation  study  indicates  that  shorter  validity  periods  and  the  requirement  for 
professional  drivers  to  undergo  regular  medical  checks  are,  in  general,  considered  to  lead  to 
potentially higher costs for citizens and a higher administrative burden, given the requirement 
for citizens to renew their driving licences and to bear the corresponding costs (e.g. for medical 
exams).  

The harmonised rules on administrative validity periods 

The analysis led to mixed findings concerning the potential costs generated by the introduction 
of the harmonised rules  on administrative validity  periods.  In the implementation  study more 
than half of the Member States assessed the new rules to  have had no effect  on the costs for 
citizens  for first  issuing, exchange or  replacement  of driving licences.  Two Member States196 
considered  the  costs  to  have  decreased  when  it  comes  to  renewal.  On  the  other  hand  Desk 
research and interviews with national authorities197, indicated that shorter validity periods led to 
increased costs for citizens and an administrative burden, particularly in Member States which 
had unlimited validity periods before the directive applied, since the directive now requires that 
licences be renewed every 10 or 15 years.  

The  directive  stipulates  that  driving  licences  for  categories  A  and  B  shall  have  an 
administrative  validity  period  of  10  years,  but  Member  States  may  choose  to  issue  such 
licences with an administrative validity period of up to 15 years. The directive further stipulates 
that driving licences for categories C and D have an administrative validity period of 5 years. 
According to the directive, the renewal of a driving licence upon expiry of the administrative 
validity period is subject to continued compliance with the minimum standards of physical and 
mental  fitness  for  driving  set  out  in  Annex  III  to  the  directive,  and  normal  residence  in  the 
territory  of  a  Member  State  issuing  the  licence.  The  directive  stipulates  that  when  renewing 
driving  licences  in  categories  A  and  B,  Member  States  may  require  an  examination  applying 
the minimum standards of physical and medical fitness. The directive allows Member States to 
limit  the  administrative  validity  period  of  the  licence  for  novice  drivers,  and  also  for  drivers 
who have reached the age of 50, to improve road safety.  

Concerning the harmonised rules on administrative validity periods, the implementation study 
found that more than half of the Member States assessed the new rules to have had no effect on 

195   AT, CZ, DE, IT, LV, LT, LU, NL, SK, SI, ES and SE. 
196   PT and HU. 
197    BE, NL, SI, FI, DK, GR and BG. 

52 

 
                                                           
the  costs  for  citizens  for  first  issuing,  exchange  or  replacement  of  driving  licences.  Two 
Member States198 considered the costs to have decreased when it comes to renewal. 11 Member 
States indicate that the costs have increased in the case of renewal.199 

Desk research and interviews with national authorities200, indicated that shorter validity periods 
led to increased costs for citizens and a higher  administrative burden, particularly in Member 
States  which  had  unlimited  validity  periods  before  the  directive  started  to  apply,  since  the 
directive now requires that licences be renewed every 10 or 15 years.  

The majority of the national  authorities interviewed indicated that the uniform  administrative 
validity and the medical fitness requirements increased the administrative costs and the burden 
for national authorities and also for citizens. Interviews with non-governmental stakeholders201 
further corroborated this finding as interviewees indicated that the costs are generally higher for 
citizens due to the limited validity periods. 

Despite the increase in costs, national authorities still viewed the changes positively due to the 
benefits  emerging from the harmonised rules  on  administrative validity periods  – particularly 
the  free  movement  of  persons  and  the  reduction  of  fraud.  Non-governmental  stakeholders202 
were of the same opinion. 

When  it  comes  to  the  costs  and  burden  incurred  by  professional  drivers,  the  open  public 
consultation  indicates  that  the  general  perception  is  that  the  introduction  of  shorter 
administrative validity periods led to higher costs.  

Concerning the rules on progressive access to category A driving licences 

The  analysis  signals  that  the  level  of  complexity  of  the  system  for  progressive  access 
introduced  by  the  directive  has  led  to  increased  costs203  for  applicants,  although  some 
stakeholders consider that the advantages in terms of road safety outweigh the costs. 

Under the directive, an applicant wishing to obtain a full category A licence will have to take 
more  training  modules  and  more  tests,  resulting  in  an  increase  in  the  total  cost204.  Estimates 
provided by the Federation of European Motorcyclists estimates that the costs for obtaining an 
A licence in Europe can range between EUR 800 to EUR 3,000. 

The  targeted  survey  with  non-governmental  stakeholders  further  supports  the  finding  that 
overall there was an increase in the costs and requirements associated with category A licences 
under the graduated access system.  

198   PT and HU. 
199   AT, BE, HR, FI, DE, IE, LV, NL, PL, ES and SE. 
200   BE, NL, SI, FI, DK, GR and BG. 
201   FEMA, FIA, FIM, EFA,, IRU, ETF, BVF, IFMC, and ACEM. 
202   BVF, FIA, ACEM, EFA, FIM 
203   Although those costs cannot be quantified based on available information 
204   In DE, higher costs for the A driving licence are applied, but lower costs apply for an AM licence; in the LU, the total costs are higher 

because of the combination of A2 and A to get a full category A licence; in the NL, the costs are higher due to the requirement to pass 4 
theoretical and practical tests for progressive access; in SE, additional costs are incurred for a practical driving test. 

53 

 
                                                           
In  the  interviews,  most  national  authorities  stated  that  the  directive  resulted  in  higher  costs205 
and waiting times for obtaining a licence  under the progressive access  system. One  authority 
said that despite the higher costs, the progressive access system does not impose a significant 
burden  on  applicants206.  Two  authorities  207reported  no  major  changes.  National  authorities208 
also  highlighted  certain  benefits  related  to  the  system  of  progressive  access  to  category  A 
licences,  particularly  when  it  comes  to  road  safety,  due  to  increased  focus  on  training  and 
examination through the staged approach. One authority209 considered there to be no evidence 
that  the  progressive  access  system  contributed  to  better  education,  training  curricula  or  road 
safety.  

The possible existence of significant differences in costs between Member States 

EQ 10: Are there any significant differences in costs between the Member States, and what is causing them?  

Driving licence fees 

The analysis found significant variation in the cost of driving licence fees applied in Member 
States. 

The directive does not contain any provisions directly regulating the cost of driving licences or 
training, such costs are entirely within the remit of Member States. 

First-time application 

Significant differences are found in the  driving licence fees incurred in  Member States.  For a 
first-time application, they vary between EUR 175 and EUR 6 (categories A, B) and between 
EUR 218 and EUR 8 (categories C and D). For exchange, the fees vary between EUR 145 and 
EUR 7 (categories A, B) and between EUR 208 and EUR 7 (categories C and D). 

205   BE, NL, FI, GR, DK and NL. 
206   DE. 
207   SI and BG. 
208   SI, FI, GR, BG and DE. 
209   NL. 

54 

 
                                                           
Costs for first time driving licence application (as % of GDP per capita) (2019)  

Source: based on Eurostat and road safety statistics 

Costs for driving licence renewal 

Citizens incur approximately 30% lower costs as compared to first application when renewing 
their driving licence, and the average cost for renewal ranges between EUR 31 (for category A 
progressive  access)  and  EUR 34 (for  category D). The main  causes for variation in  costs are 
associated  with 
level  of  efficiency  of  national 
administrations. 

the  national  requirements  and 

the 

Costs for driving licence renewal (as % of GDP per capita) (2019) 

55 

 
 
 
 
 
 
 
 
 
Differences  in  costs  and  fees  applied  by  the  Member  States  are  most  likely  explained  by  the 
set-up  of  the  administrations  when  it  comes  to  taxation  rules  and  the  set-up  and  levels  of 
efficiency  of  the  administrations.  According  to  the  implementation  study210,  most  Member 
States  (20  out  of  27)  have  driving  licence  systems  that  are  solely  run  by  the  public 
administration.  Four  Member  States211  involved  private  service  providers.  However,  when 
comparing the fees of public versus private providers there seems to be no clear indication of 
the efficiency of one model over the other. 

Fees for exchange driving licences 

The fees  applied for exchange of third country driving licences are on average slightly lower 
than  the  fees  for  first  time  issuance  of  a  driving  licence.  Citizens  that  exchange  their  third 
country driving licence pay on average between EUR 46 for exchanging a category D driving 
licence, and EUR 28 for exchanging a third country driving licence through direct access212.  

Training costs  

The  analysis  evidences  that  there  are  substantive  differences  in  terms  of  the  training  costs 
across Member States. 

For instance, the costs of obtaining a category A driving licence, through progressive access, 
varies  between  EUR  300  in  Greece  and  EUR  2,000  in  Luxembourg.  The  training  costs 
associated with obtaining a category A driving licence through direct access are substantively 
lower and vary from EUR 200 in Latvia and Hungary to EUR 600 in Luxembourg and Norway.  

Training  costs  associated  with  category  B  licences  also  tend  to  vary  across  Member  States, 
ranging from EUR 420 in Ireland to EUR 2,000 – 2,500 in countries such as Denmark, Finland, 
Luxembourg, and Norway.  

Similarly, training costs for category C and D licences vary widely. In the upper range, costs 
vary from EUR 2,000 up to EUR 4,000 in countries such as Denmark, Finland, Norway, and 
Luxembourg. In the lower range, training costs can be as low as EUR 500 in Ireland.  

The differences in training costs can be explained by differences in the training requirements in 
terms of the number of lessons (theoretical and practical, formal or informal) and the national 
and  regional  specificities  in  terms  of the  market  for  the  provision  of  driving  licence  training. 
Finally, cost differences are also driven by other national requirements related to the training or 
preparation for the examination. Such costs can include costs for specialised training (e.g. cost 
of first aid course), costs for medical examinations and ophthalmologist checks, administrative 
costs (e.g. photo  cost,  municipality fees), costs for test  repetition,  and  costs for an interpreter 
(where needed).  

210   European Commission (2017), The implementation of  Directive 2006/126/EC on driving licences. Report drafted by Hasselt University, 

NTUA. 

211   FI, IE, LT and MT 
212   You can obtain your full (category A) motorcycle licence using the direct access scheme if you’re aged 24 or over according  to point c) (i) 

of Article 4(3) of the directive. 

56 

 
 
                                                           
EQ 11: Is there a potential for simplification and reduction of  the regulatory burden caused by the directive, for 

instance through further digitalisation or better exploiting?  

The analysis seems to indicate that there are several areas with potential for simplification and 
reduction of the administrative burden, e.g. an administrative simplification of driving licence 
renewal;  the  medical  checks  for  professional  drivers;  the  progressive  access  to  category  A 
licences; the rules related to weight limits for category B licences (e.g. in case of motorhomes); 
and  the  administrative  processes  related  to  the  establishment  of  the  normal  residence.  Digital 
solutions such as digital driving licences are insufficiently explored at present, and the use of 
RESPER could offer further potential for reduction of the administrative burden.  

The implementation study revealed several areas of potential for simplification and reduction of 
administrative  burden;  which  is  also  confirmed  by  data  collected  in  the  targeted  surveys, 
interviews and the open public consultation. Those areas are the following: 

  The progressive access to category A licences which is perceived by the users as highly 

complex and costly  

  The requirements related to normal residence could be further simplified213. 

  Some  stakeholders  indicated  that  they  perceive  the  current  weight  limit  of  category  B 
licences  (3,500  kg)  as  imposing  unnecessary  burdens  on  motorhomes  and  other  larger 
service vehicles and may lead to additional costs.214. 

  Digital  solutions  and  digitalisation  of  driving  licences  are  insufficiently  explored.  The 
survey with the national authorities revealed that digital driving licences are issued in only 
six  countries215.  National  authorities  and  non-governmental  stakeholders216  also  indicated 
that  there  is  a  general  interest  in  introducing  digital  driving  licences.  However,  there  are 
currently  no  common  EU  standards  related  to  digital  driving  licences  and  also  no  clear 
guidelines  in  the  directive217.  Moreover,  the  roll-out  of  digital  driving  licences  may  also 
lead to additional costs both for authorities and citizens218.  

213   Interviews  with  national  authorities  of  BE,  SI  and  DK,  highlighted  that  checking  compliance  with  the  rules  for  normal  residence  is 

cumbersome both for the authorities and for citizens. 

214   IFMC,  European  Caravan  Federation.  According  to  the  IFMC,  85%  of  the  fleet  that  is  running  on  the  roads  is  running  overload. 
Specifically, motorhomes are checked relative to the weight limit and penalties are imposed for those that do not comply. The penalties 
that are applied can vary: in DE - 235 EUR, ES - 4,600 EUR and AT - 5,000 EU. 

215   Norway, Iceland, DK, ES ,PL and PT  
216   FIA, IFMC, BVF. 
217   FI, DE, LU, NL, SE 
218   Norway, Iceland and ES. 

57 

 
 
 
 
 
                                                           
5.3.Relevance  

This subsection assesses whether the objectives of the directive are still in line with the current 
needs or problems, how the situation/context as regards the provision of the directive in the EU 
has evolved and whether the directive still matches current needs. It also assesses whether its 
scope  is  still  fit  for  purpose;  and  whether  the  four  key  areas  currently  covered  under  the 
technical  guidelines  and  specifications  are  sufficient  to  respond  to  the  evolved  needs,  given 
technological developments. 

The future proof of the directive 

EQ  12:  Do  the  objectives incorporated in  the  directive  match the  needs  of today  and  the  foreseeable 

future? 

The  analysis  indicates  that  the  objectives  of  the  directive  are  still  relevant,  but  the  means  to 
achieve  those  objectives  need  to  be  updated,  especially  when  it  comes  to  raising  the  drivers’ 
skills. The current provisions on driving education and testing do not seem to have matched the 
pace of technological development, both in terms of vehicle technology (advanced safety  and 
efficiency  features,  alternative  fuels,  intelligent  transport  systems,  automated  driving,  and 
micro-mobility solutions) and digital information. 

The  implementation  study  pointed  to  the  fact  that  the  current  and  future  needs  arising  from 
rapid technological and legal developments affected the scope of the directive.219 

The stakeholders consulted in targeted consultations generally assessed the current directive as 
not sufficiently adapted to the use of technological advances such as advanced driver assistance 
systems,  alternative  fuel  vehicles,  intelligent  transport  systems,  and  automated  driving 
functions. The results of the survey with non-governmental authorities can be found in Annex 
V (Table 5). 

In  the  open  public  consultation,  the  opinions  were  more  split  when  it  came  to  the  extent  to 
which knowledge requirements for obtaining a driving licence are adapted to new technologies. 
Slightly  more  than  50%  (282)  of  the  respondents  considered  the  requirements  to  obtain  a 
driving licence to be adapted to a great extent or to a some extent. At the same time, 38% (206) 
of respondents assessed that the requirements were “very little” or “not at all” adapted to new 
technologies  fitted  to  vehicles.  Opinions  were  split  across  the  various  types  of  stakeholders. 
Notably,  a  large  proportion  of  EU  citizens,  NGOs  and  trade  unions  considered  the  driving 
licence requirements to be “very little” or “not at all” adapted to new technologies. 

219   European Commission (2017), The implementation of  Directive 2006/126/EC on driving licences. Report drafted by Hasselt University, 

NTUA. 

58 

 
 
 
 
                                                           
The appropriateness of the current age limits  

EQ 13: Are the minimum age limits established in the directive appropriate for current social needs? 

The analysis of existing studies, statistical analysis of road safety for  young riders and drivers 
and  the  results  from  the  interview  and  survey  analysis  indicate  that  the  minimum  age  limits 
established in the directive are broadly adequate. However, a few suggestions were put forward 
to better reflect social needs in this regard.  

The  directive  (article  4)  provides  a  lot  of  flexibility  to  Member  States  when  it  comes  to 
establishing the minimum age at which a person is allowed to drive. The directive only sets a 
minimum  age  depending  on  the  category  of  driving  licence  (it  ranges  from  16  years  old  for 
category AM, to 24 years old for categories D and DE). In certain instances, the directive even 
allows Member States to raise or lower the minimum age limits applicable in their territory.  

The literature indicates that the inexperience and young age of drivers are the most important 
factors leading to the overrepresentation of young and novice drivers in traffic accidents220.  

For  this  reason,  accompanied  driving  for  the  category  B  licence  is  regarded  positively  in 
existing  research  and  by  the  stakeholders  consulted.  Some  Member  States’  authorities  also 
supported the idea of regulating accompanied driving at EU level, in particular for category B 
licences. 

In the survey, the majority of non-governmental stakeholders (20 out of 36) indicated that the 
minimum age limits are appropriate. 12 respondents disagreed with this statement, and 4 could 
not provide an assessment. A large proportion of respondents (20 out of 41) indicated that there 
are no particular issues concerning the interpretation, application, and enforcement of minimum 
age limits in the directive, while more than a third (14) perceived the opposite to be true. 

In  this  context,  stakeholders  representing  transport  employers  have  advocated  reducing  the 
minimum  age  for  accompanied  driving  in  a  professional  context221.  Regarding  professional 
driving,  this  question  is  linked,  and  should  be  assessed  in  conjunction  with  the  provisions  of 
directive 2003/59/EC on the initial qualification and periodic training of truck and bus drivers. 
directive 2003/59/EC provides for the possibility to lower the minimum age for category C and 
D driving licences under certain conditions (if they have completed a 280 hour training course).  

220   European Commission (2017), Study on driver training, testing and medical fitness. Report drafted by TRL, SWOV, BASt, Loughborough 

University, Monash University. 

221   IRU suggested reducing the minimum age for trained young professional truck drivers to 17 years under the condition that they were duly 
accompanied by a competent and experienced professional driver. This contrasts with another respondent (ETF), that considers reducing 
the minimum age for professional drivers to under 18 would not be favourable. The latter respondent further explained that the industry is 
pushing for a lower minimum age with the argument that this would solve the issue related to the shortage of drivers, however the latter 
respondent  believed  that  the  shortage  of  drivers  is  caused  by  other  factors,  e.g.  general  working  conditions  that  are  not  particularly 
appealing for young people. 

59 

 
 
 
 
                                                           
Are current and future road users covered by the scope of the directive? 

EQ 14 To what extent are all the types of current or potential road users covered by the directive, given 
new  mobility solutions such  as  micro-mobility and  electric  bicycles  and scooters?  Are  there 
significant differences among Member States, or among age groups? 

The  analysis  indicates  that  not  all  types  of  current  road  users  are  covered  by  the  directive, 
especially in  the case of new mobility solutions,  such as micro-mobility  and electric bicycles 
and scooters. 

New transport modes, offering new solutions of micro-mobility such as electric scooters, bikes 
and mopeds have increased in  popularity among road users. Such new forms of transport are 
acknowledged  by  the  European  Commission  in  its  Communication  'Road  Safety  Vision 
Zero'222 as both an opportunity as well as a challenge in terms of ensuring a safe framework 
for  their  use.  Under  the  current  EU  driving  licence  rules,  an  AM  driving  licence  (or  higher 
category, depending on maximum design speed and the maximum continuous power  level) is 
required for electric bicycles with a maximum speed above 25 km/h. However, presently there 
is no EU framework regulating such new micro-mobility forms and Member States have been 
regulating such new micro-mobility forms in different manners. 

Consulted stakeholders raised concerns related to the absence of an EU common framework for 
regulating new micro-mobility solutions  in  particular when it comes to  road safety. Evidence 
from interviews with non-governmental stakeholders and national authorities point to the fact 
that  the  use  of  micro-mobility  devices  should  not  be  regulated  at  EU  level,  in  particular  that 
there is no need to an EU regulation concerning the driving licence for micro-mobility devices. 

In the survey with non-governmental stakeholders the majority of stakeholders (21 out of 28223) 
disagreed  or  strongly  disagreed  that  the  directive  sufficiently  addresses  micro-mobility 
solutions.  

Given that there is no legal framework at EU level for traffic rules, the use of micro-mobility 
devices such as electric scooters or e-bikes is not regulated at EU level. Under the directive, a 
driving licence of category AM is required for two and three-wheel vehicles with a maximum 
speed  above  25  km/h.  Therefore  most  micro-mobility  devices  fall  outside  the  scope  of  the 
directive.  

Nevertheless,  evidence  from  interviews  with  non-governmental  stakeholders  and  national 
authorities does not unanimously point to a view that such micro-mobility solutions should be 
regulated  at  EU level.  Whereas some stakeholders indicate that there is a need for regulating 
the area due to  the safety  challenges it poses, other stakeholders  identified the need for more 
evidence before concrete recommendations are put forward.  

222   Commission Staff Working Document 'EU Road Safety Policy  Framework 2021-2030 – Next steps towards 'Vision Zero', SWD (2019) 

283 final. 

223   4  automotive  and  motorcycle  federations,  4  driving  school  associations,  7  road  safety  and  road  users’  associations,  7  'other',  1  vehicle 

manufacturers’ association.  

60 

 
 
                                                           
In this legal context, Member States have, over the past three or four years, gradually adopted 
national  legislation  defining  the  rules  for  the  use  of  micro-mobility  devices.  Most  Member 
States do not require a driving licence for this type of vehicle. 

Adaptation of the directive to demographic trends  

EQ  15  To  what  extent  are  the  provisions  on  driving  licence  renewal  adapted  to  demographic  trends 

such as an ageing population? 

The analysis indicates the importance of considering the safety of older drivers. However, this 
should not  compromise the possibility  for them to remain  active and independent  at  an older 
age.  There  is  no  conclusive  evidence  that  fitness  screening  based  on  age  provides  significant 
road safety benefits. However, stakeholders have indicated that more attention should be paid 
to the high health-risk drivers. Another conclusion of the analysis is that the increased mobility 
of citizens within the EU is causing difficulties  in obtaining a driving licence in  situations of 
insufficient command of the official language of the country of residence. 

Europe is increasingly being faced with the challenge of population ageing. There are no upper 
age limits in the European Union for holding a driving licence.  

The  study  on  driver  training,  testing  and  medical  fitness224  suggests  that  there  is  a  lack  of 
evidence that a general age-based system, and currently available screening assessments, have 
substantial safety benefits.  

In  the  survey,  non-governmental  stakeholders  considered  whether  the  directive  addresses  the 
current and  future needs of an ageing population.  16 out  of 41225  respondents  considered  that 
the directive addresses current and future needs, while 9 out of 41 consider that it does not226. 
However (when disregarding 12 respondents who could not provide an assessment) more than 
half  of  the  remaining  respondents  (16  out  of  29)  disagreed  or  strongly  disagreed  that  the 
directive  has  led  to  improved  road  safety  for  older  drivers,  while  slightly  less  than  half 
indicated that road safety has been improved for older drivers. According to the respondents, a 
medical examination upon renewal should be required for driving licence holders of all driving 
licences and should not be based on self-declaration.  

In  the  interviews  with  national  authorities,  three227  respondents  indicated  that  the  directive 
provides  sufficient  opportunity  for  Member  States  to  impose  medical  check-up  requirements 

224   European Commission (2017), Study on driver training, testing and medical fitness. Report drafted by TRL, SWOV, BASt, Loughborough 

University, Monash University. 

225   1 automotive and motorcycle federations, 1 drivers association, 6 drivers school associations, 5 road safety and road users associations, 1 

vehicle manufacturer association, 2 'other category'. 

226   3 automotive and motorcycle federations, 3 road safety and road users associations, 1 vehicle manufacturer association, 3 'other category'. 
227   BG,GR and SI 

61 

 
 
                                                           
according to their own national contexts and 3 other respondents228 indicated that more could be 
done in this regard. 

In the interviews with non-governmental stakeholders, several expressed concerns in terms of 
the  balance  between  safety  requirements  and  the  need  for  the  older  generation  to  stay  active 
and  mobile.  3  stakeholders  made  the  point  that  older  drivers  must  have  the  possibility  of 
remaining mobile229, and 2 expressed their concerns regarding age-based medical screening230. 

The existing research has showed that the fatality rate for the category of drivers aged above 75 
years  is  the  second  highest  among  all  age  groups231.  However,  this  higher  fatality  rate  is  to  a 
significant extent the result of physical vulnerability, rather than higher crash risk. In any case, 
a  medical  examination  is  currently  required  by  the  directive  for  drivers  holding  licences  of 
categories C and D and some Member States have extended this obligation to categories A and 
B. 

In the context of an increased mobility of citizens within the EU, it is becoming more common 
for some citizens to experience difficulties in obtaining a driving licence because they do not 
have a sufficient command of the official language of the Member State where they have their 
normal  residence. This  can be the case  for EU  and non-EU nationals, as  outlined in  citizens’ 
questions  and  complaints  handled  by  the  Commission.  This  is  despite  the  fact  that  some 
Member States offer exams in languages other than their official language(s). 

228   BE,FI and NL 
229   FIA, CIECA and ETSC 
230   FIA and ETSC 
231   European Commission (2018). Older drivers, p. 4: https://ec.europa.eu/transport/road_safety/system/files/2021-07/ersosynthesis2018-

olderdrivers.pdf 

62 

 
 
 
                                                           
5.4  Coherence 

This  subsection  assesses  whether  the  directive  is  internally  consistent  and  whether  the 
legislation  is  consistent  with  relevant  EU  and  international  interventions  in  the  area  of 
transport, road safety, automation, digitalisation and type-approval. 

5.4.1 

Internal coherence of the provisions of the directive 

EQ 16: To what extent are the provisions of the directive coherent and consistent with one another? Are 

there any overlaps, contradictions or inconsistencies?  

In  general  terms,  the  analysis  does  not  find  any  substantial  inconsistencies  among  the 
provisions of the  directive. That  said, some stakeholders pointed minor inconsistencies in the 
equivalence rules and in the insufficient precision of Annex III on standards on alcohol, drugs 
and medicinal products. 

In this section we analyse the internal coherence of the directive, namely if the provisions of 
the directive are coherent and consistent with one another, or if there are any overlaps, 
contradictions or inconsistencies between its different articles and annexes. 

During  interviews,  5  out  of  9  national  authorities  did  not  believe  that  major  inconsistencies 
exist  within  the  directive.232  3  authorities233  mentioned  the  difficulty  in  applying  the  rules  on 
normal  residence.  One  Member  State234  mentioned  some  inconsistency  regarding  the 
equivalence  rules.  For  instance,  the  category  DE  driving  licence  allows  the  holder  to  drive  a 
category  D1E  vehicle,  whereas  CE  licence  does  not  provide  the  same  opportunity  to  drive  a 
category  C1E  vehicle.  The  implementation  study  also  noted  that  the  provision  on  normal 
residence needs to be fine-tuned to be more easily and more consistently applied235.  

In the survey with non-governmental stakeholders and in interviews with national authorities, it 
was suggested that the Standards on Alcohol and Drugs and Medicinal Products (points 14 and 
15  of  Annex  III  to  the  directive)  could  be  more  precise;  the  provisions  related  to  diabetes 
mellitus (point 10 of Annex III) were also found to be in need of an update. 

232   BE, BG, FI and SI. 
233   GR and NL. 
234   NL 
235   The problems related to the definition of normal residence are fully detailed in section 5.1.2.7 (Positive and negative unexpected effects of 

the directive. 

63 

 
 
 
 
                                                           
5.4.2  External coherence of the directive with other legislation 

Relevant questions to assess this objective 

EQ  17  Are  there  any  inconsistencies/gaps/overlaps  between  the  directive  and  other  legislation  at 
international  level  which  has  similar  objectives,  and  in  particular  with  the  relevant 
international obligations of the Member States?  

EQ 18.1 To what extent is the directive coherent with other EU legislation in the area of road safety? 

EQ 18.2 To what extent is the directive coherent with other EU transport legislation, in particular in the 
areas  of  automated  driving  and  digitalisation  policies  (for  example  the  Cooperative, 
connected and automated mobility or the digital transport)? Are there any overlaps, gaps or 
inconsistencies? Are there any complementarities/synergies? 

EQ 18.3 To what extent is the directive coherent with other EU legislation such as motor vehicle type-
approval  legislation,  the  Digital  Single  Market  and  e-Government  initiatives  in  relation  to 
digitalisation? 

5.4.3  Coherence with international legislation 

The analysis points to a general coherence with the 1949 Geneva Convention236 on Road Traffic 
and the 1968 Vienna Convention on Road Traffic237, despite some punctual inconsistencies.  

In the last century, the obligation to hold a driving licence in order to be able to drive came into 
effect. The Geneva Convention on Road Traffic of 1949 and the Vienna Convention on Road 
Traffic  of  1968  laid  down  uniform  road  traffic  rules  facilitating  international  road  traffic  and 
thereby also increasing road safety. Both conventions specified that drivers of a motor vehicle 
must be in possession of a valid driving permit if they want to drive in other countries. 

The  general  coherence  of  the  directive  with  the  Geneva  Convention  on  Road  Traffic  and  the 
Vienna  Convention  on  Road  Traffic,  was  confirmed  in  the  interviews  by  6  out  of  9  national 
authorities.238 3 national authorities239 explained that there is some inconsistency with those two 
Conventions  as  they  did  not  fully  allow  automated  vehicles  and  their  requirements  on  the 
driving licence format were outdated. 

A study240 highlighted some discrepancies between the categories of the directive and those of 
the 1968 Vienna Convention on Road Traffic, the latter being less restrictive241.  

236   United Nations Convention on Road Traffic Geneva, 19 September 1949- 

(https://treaties.un.org/Pages/ViewDetailsV.aspx?src=TREATY&mtdsg_no=XI-B-1&chapter=11&Temp=mtdsg5&clang=_en) 

237   United Nations Convention on Road Traffic Vienna, 8 November 1968 

(https://treaties.un.org/pages/ViewDetailsIII.aspx?src=TREATY&mtdsg_no=XI-B-19&chapter=11) 

238   BG, DE, DK, FI, NL and SI.  
239   BE, GR and ES 
240   UNECE (2017), International Driving Permit Categories – 1968 Convention on Road Traffic. Available at: 

https://unece.org/DAM/trans/main/wp1/wp1doc/International_Driving_Permit_Categories.pdf 

64 

 
 
                                                           
In the survey with non-governmental stakeholders, two respondents mentioned that the relevant 
UN conventions  lack the A2 driving licence  category  and pointed to inconsistencies between 
the directive and the Vienna Conventions or UNECE regulations in relation to highway codes 
(road signs and rules).  

5.4.4  Coherence with other EU legislation in the area of road safety and transport 

The analysis indicates that the directive is broadly consistent with the EU legislation in the area 
of road safety analysed for this evaluation, namely: 
a) Directive 2003/59/EC (amended by Directive (EU) 2018/645) on the initial qualification and 
periodic training requirements for professional drivers of trucks and buses; 
b)  Directive  2015/413/EU  on  cross-border  exchange  of  information  on  road  safety  related 
traffic offence (CBE directive); and 
c) Regulation (EC) No 661/2009 (General Safety Regulation)242. 

No  major  coherence  issues  were  observed,  and  the  majority  of  the  consulted  stakeholders 
agreed that the directive is broadly coherent with other legislation on road safety. Nevertheless, 
some punctual issues were identified in the evaluation as mentioned below. 

Directive  2003/59/EC  (amended  by  Directive  (EU)  2018/645)  on  the  initial  qualification 
and periodic training requirements for professional drivers of trucks and buses 

The  Impact  Assessment243  that  accompanied  the  proposal  to  amend  Directive  2003/59/EC244 
highlighted  that  the  minimum  age  to  access  the  profession  could  lead  to  discrepancies  that 
could distort competition in the EU, as enterprises in countries that were able to hire younger 
professional  drivers  had  a  much  larger  pool  of  potential  drivers  to  hire  from  compared  to 
companies based in other countries.  

The  legislative  proposal  mentioned  above  resulted  in  Directive  (EU)  2018/645245  which  was 
adopted  in  April  2018  and  which  amended  both  Directive  2003/59/EC  and  Directive 
2006/126/EC  with  a  view  to  providing  legal  clarity  as  regards  the  minimum  age  for  certain 
driving  licence  categories.  It  provided  for  a  clear  derogation  in  Directive  2006/126/EC, 
allowing for category C and D driving licences to be issued at the minimum ages provided for 

241   For example, EU licence category B1 permits only quadricycles to be driven by the holder of a B1 driving licence, whilst the Convention 

allows tricycles and quadricycles to be driven by the holder of a B1 driving permit 

242   Regulation (EC) No 661/2009 of the European Parliament and of the Council of 13 July 2009 concerning type-approval requirements for 
the general safety of motor vehicles, their trailers and systems, components and separate technical units intended therefor. This regulation 
will be replaced by the revised General Safety Regulation (EU) 2019/2144 on 6 July 2022 

243   Commission  Staff  Working  Document:  Impact  Assessment  accompanying  the  document  Proposal  for  a  Directive  of  the  European 
Parliament and of the Council amending Directive 2003/59/EC on the initial qualification and periodic training of drivers of certain road 
vehicles for the carriage of goods or passengers and Directive 2006/126/EC on driving licences (COM(2017) 47 final). 

244   And also Directive 2006/126/EC 
245   Directive (EU) 2018/645 of the European Parliament and of the Council of 18 April 2018 amending Directive 2003/59/EC on the initial 
qualification and periodic training of drivers of certain road vehicles for the carriage of goods or passengers and Directive 2006/126/EC on 
driving licences (OJ L 112, 2.5.2018, p. 29). 

65 

 
 
 
 
 
                                                                                                                                                                                        
in Directive 2003/59/EC on the initial qualification and periodic training of drivers of certain 
road vehicles for the carriage of goods or passengers.  

However, in the survey of non-governmental stakeholders it was mentioned that minimum age 
limits  are too  high for some professional  driving licence categories and  these are  not  aligned 
with  the  philosophy  of  the  EU  recommendation  on  professional  training  and  skills 
development246,  namely  the  European  qualifications  framework  which  grants  a  fundamental 
role  to  the  notion  of  learning  outcomes  based  on  the  skills  acquired  and  not  the  age  of  the 
learner. The survey results indicated that there is still some room for improvement concerning 
Directive  2003/59/EC  in  particular  in  relation  to  the  potential  recognition  of  driver 
qualifications acquired in a third country, and further harmonisation on the minimum age.  

The majority of respondents to the public consultation (36%)247 did not raise concerns regarding 
coherence with the legislation on training and certification of professional drivers, as they have 
not  faced  any  issues  in  this  regard.  Respondents  of  Dutch  origin  tended  to  increase  the 
percentage  of  respondents  who  were  faced  with  problems  in  this  category.  When  omitting 
Dutch  respondents,  who  represent  a  significant  majority  of  the  overall  respondents,  the 
percentage  of  respondents  who  have  been  faced  with  issues  regarding  the  training  and 
certification of professional drivers due to incoherence between the directive and the legislation 
presented in the questionnaire fell from 36% to 29%. 

Directive (EU) 2018/645 has also laid out the requirement to issue a driver qualification card to 
ensure  mutual  recognition  of  completed  periodic  training,  as  per  Directive  2003/59/EC,  for 
every  driver  in  the  event  that  completed  training  cannot  be  marked  on  the  driving  licence. 
Previously,  some  drivers  wanting  to  follow  the  periodic  training  in  another  Member  State 
where they commuted to work, were unable to have the training recognised, because only the 
Member State where the driver resided was entitled to issue a driving licence. Certain Member 
States  did  not  issue  a  driver  qualification  card,  and  they  were  thus  unable  to  provide  the 
mutually  recognised  Code  95248  for  a  resident  in  another  Member  State  who  had  undergone 
periodic training on their territory. This was partly addressed during the interviews since some 
stakeholders suggested that the requirements set out in Directive 2003/59/EC should be taken 
into  greater  consideration249.  For  example,  the  validity  periods  of  Code  95  are  currently  not 
entirely aligned. 

246   Council  Recommendation  of  24  November  2020  on  vocational  education  and  training  (VET)  for  sustainable  competitiveness,  social 

fairness and resilience (2020/C 417/01), OJ C 417, 2.12.2020, p. 1 

247   199 out 546 respondents. 
248   The  directive  uses  letters  to  identify  the  different  categories  of  driving  licences  (for  ex:  A,  B,  C,  D  etc.)  but  it  also  further  refines  the 
conditions  to drive  by using  (if needed)  harmonised European  Union  codes  (from  01 to 99),  or  a national codes  (codes 100  and above, 
valid only for driving in the territory of the Member State which issued the licence). These codes are printed on the back of the driving 
licence.  A  code  95  is  an  EU  code  that  certifies  that  the  professional  freight  and  passenger  transport  driver  went  through  appropriate 
training and test and therefore possess a driver Certificate of Professional Competence. 

249   FI, DE and ETF. 

66 

 
 
 
                                                           
Directive  2015/413/EU  on  cross-border  exchange  of  information  on  road  safety  related 
traffic offence (CBE directive) 250 

The  European  Commission’s  implementation  study251  of  2016  on  the  application  of  the  CBE 
directive concluded that this directive complements the driving licence directive, as it ensures 
awareness of, and compliance with, road traffic rules in force in Member States different to the 
Member  State  of  residence,  and  is  thus  filling  a  legal  gap  regarding  the  cross-border 
enforcement  of  road  traffic  rules.  The  Commission  is  currently  finalising  the  analysis  on 
whether  the  CBE  directive  could  be  further  improved  to  better  support  the  enforcement  of 
mutual recognition of driving disqualifications252. 

In regard to the legislation on cross-border enforcement of traffic rules, most respondents to the 
public consultation  (287 put  of 546) indicated that they have not  faced  any issues  in  the past 
due to potential incoherence with the directive. 

Regulation (EC) No 661/2009 and Regulation (EU) 2019/2144 (General Safety Regulation)  

In the survey with non-governmental stakeholders one stakeholder also pointed out a possible 
inconsistency  between  the  directive  and  the  revised  General  Safety  Regulation  (replacing  the 
current one on 6 July 2022). The General Safety Regulation mandates that all new cars put on 
the market as of July 2022 will have to be equipped with a set of mandatory advanced safety 
systems (ADAS). As a result, according to those stakeholders the revised directive should give 
special consideration to current and future technological advances such as ADAS. 

The  implementation  study253  pointed  to  the  need  to  improve  driver  education  and  tailor  it  to 
technological advances, to consider the limitations of the current framework when it comes to 
automated  driving,  and  to  consider  the  need  for  increased  sustainability  which  may  prompt 
users to  consider environmentally-friendly mobility solutions,  such as  electrically powered or 
other  alternative  fuelled  vehicles.  The  feedback  from  interviews  has  pointed  out  that  the 
education requirements do not cover ADAS, or new vehicles such as light mopeds. 254 

In  the  same  regard,  the  Report  of  the  High-Level  Group  on  the  Competitiveness  and 
Sustainable  Growth  of  the  Automotive  Industry  in  the  European  Union  (GEAR  2030)255 
suggested that driver education is vital for the successful implementation of highly automated 

250   Directive  (EU)  2015/413  of  the  European  Parliament  and  of  the  Council  of  11  March  2015  facilitating  the  cross-border  exchange  of 

information on road safety related traffic offences (OJ L 68, 13.3.2015, p. 9). 

251   European Commission  (2016),  Evaluation  Study  on  the  Application  of directive  2011/82/EU  Facilitating the  Cross-Border  Exchange  of 
Information  on Road  Safety  Related  Traffic  Offences  -  Final  Report.  Drafted  by  Dalila  Frisani,  Alessandro  Zamboni, Céline  Monteiro. 
https://op.europa.eu/en/publication-detail/-/publication/77b97427-3c33-11e6-a825-01aa75ed71a1/language-en  directive  2011/82/EU  has 
been replaced by directive (EU) 2015/413 which contains identical provisions but a different legal basis. 

252   In the open public consultation, with Open Public Consultation, in regard to the CBE directive, most respondents (52%) indicated that they 
have  not  faced  any  issues  in  the  past  due  to  potential  incoherence  with  the  directive,  whereas  11%  (i.e.  62)  of  respondents  stated  the 
opposite  to  be  true.Furthermore,  the  majority  of  respondents  (36%)  did  not  raise  concerns  regarding  coherence  with  the  legislation  on 
training and certification of professional drivers, as they have not faced any issues in that regard. 

253   European Commission (2017), The implementation of  Directive 2006/126/EC on driving licences. Report drafted by Hasselt University, 

NTUA. 

254   FIA, EFA and ETSC. 
255   GEAR 2030. High Level Group on the Competitiveness and Sustainable Growth of the Automotive Industry in the European Union, Final 
Report  –  2017.  https://ec.europa.eu/docsroom/documents/26081/attachments/1/translations/en/renditions/native  European  Commission, 
2017. 

67 

 
 
                                                           
vehicles. According to the report, the current rules concerning training do not sufficiently cover 
automated vehicles in situations where the vehicle requests the human driver to take control in, 
for example, extreme weather conditions, at work sites, or other unreadable situations.256  

5.4.5  Coherence  with  vehicle  type-approval  legislation,  the  Digital  Single  Market  and  e-
Government initiatives in relation to digitalisation 

The  analysis  did  not  find  major  concerns  regarding  coherence  with  type-approval  legislation, 
the Digital Single Market and e-Government initiatives.  

The analysis did not raise major concerns regarding coherence with the Digital Single Market 
and  e-Government  initiatives257,  but  the  implementation  study  and  the  analysis  of  the 
stakeholders'  feedback  during  the  interviews258  identified  a  few  consistency  problems  with 
vehicle type-approval legislation. For instance, the directive should provide a possibility to tow 
trailers  with  category  A  vehicles  (PTW  or  tricycles),  which  is  allowed  under  type  approval 
legislation259.  

In the open public consultation, more than 40%260 of the respondents reported that they have not 
faced any problems with type approval legislation, while 19%261 of the respondents have been 
faced  in  the  past  with  problems262  because  of  discrepancies  between  that  legislation  and  the 
directive. The responses were split quite evenly across different types of stakeholder. 

The  evaluation  also  points  out  that  the  directive  is  not  sufficiently  aligned  with  the  type 
approval  legislation  that  has  been  modified  (L-category  type  approval  framework)263. 

256   High Level Group on the Competitiveness and Sustainable Growth of the Automotive Industry in the European Union, Discussion paper 
https://circabc.europa.eu/sd/a/3e06f7bf-2719-4be1-9f24-

on  Highly  Automated 

vehicles. 

(rev1.1-11-06-2016),  Roadmap 
ba6b2975d7eb/Discussion%20Paper%20-%20rev.1%2004-05-2015.pdf. 

257   A  Digital  Single  Market  Strategy  for  Europe  (COM(2015)  192  final  of  6.5.2015);  Tallinn  Declaration  on  eGovernment  of  6.10.2017 
(https://lisboncouncil.net/wp-content/uploads/2020/07/tallinn_egov_declaration.pdf); Council conclusions on the digitalisation of transport 
of 5.12.2017 (https://www.consilium.europa.eu/en/press/press-releases/2017/12/05/digitalisation-of-transport-council-conclusions/);  

The  Cooperative,  connected  and  automated  mobility  initiative  (CCAM)  in  the  framework  of  the  European  Strategy  on  Cooperative 
Intelligent  Transport  Systems 
(https://transport.ec.europa.eu/transport-themes/intelligent-transport-systems/cooperative-
(C-ITS) 
connected-and-automated-mobility-ccam_en)  

258   DE and ACEM 
259   Regulation (EC) No 661/2009 of the European Parliament and of the Council of 13 July 2009 concerning type-approval requirements for 
the  general  safety  of  motor  vehicles,  their  trailers  and  systems,  components  and  separate  technical  units  intended  therefore(OJ  L  200, 
31.7.2009, p. 1) 

Regulation  (EU)  2018/858  of  the  European  Parliament and  of  the  Council  of  30 May  2018  on the  approval  and  market  surveillance  of 
motor  vehicles  and  their  trailers,  and  of  systems,  components  and  separate  technical  units  intended  for  such  vehicles,  amending 
Regulations (EC) No 715/2007 and (EC) No 595/2009 and repealing Directive 2007/46/EC (OJ L 151, 14.6.2018, p. 1) 

Regulation (EU) No 167/2013 of the European Parliament and of the Council of 5 February 2013 on the approval and market surveillance 
of agricultural and forestry vehicles(OJ L 60, 2.3.2013, p. 1) 

Regulation (EU) No 168/2013 of the European Parliament and of the Council of 15 January 2013 on the approval and market surveillance 
of two- or three-wheel vehicles and quadricycles (OJ L 60, 2.3.2013, p. 52).. 

260   224 of 546 Stakeholders. 
261   105 of 546 stakeholders. 
262   35 mentioned challenges related to the insufficient harmonisation of motorcycle licences and minimum age requirements for motorcycle 
driving licences. Furthermore, some citizens mentioned the problem related to weight-allowance of certain vehicles (campers, O1 trailers), 
which has resulted in financial and administrative burdens for both citizens and public authorities. Another coherence problem related to 
the  type  approval  legislation  is  the  fact  that  the  directive  does  not  entirely  correspond  to  three  wheeled  vehicles  categories  in  the  type 
approval legislation. 

263   ACEM written contribution 

68 

 
 
 
                                                           
According to the feedback of ACEM, new categories of vehicles introduced by the new type-
approval  regulation  should  be  aligned  with  the  driving  licence  directive.  A  new  EU-type 
approval  system  for  L-category  vehicles  (2-,  3-  and  4-wheel  vehicles  such  as  motorcycles, 
mopeds, quads, and minicars) came into force at the end of 2015, when  the EU repealed and 
replaced  the  old  directive  2002/24/EC  by  Regulation  (EU)  No  168/2013.  The  updated  rules 
include changes to the classification of the various vehicle categories. Against this background, 
there is an urgent need to re-align the two instruments. 

Based on the existing literature, the directive currently does not allow the towing of trailers by 
category A vehicles, although this is possible under the type approval legislation. Additionally, 
there is a new requirement for certain electrically assisted pedal cycles (EAPC) to obtain type 
approval but this does not require additional requirements in terms of licensing.  

Stakeholders264  also  signalled  during  the  interviews  that  the  type-approval  legislation  for 
heavier recreational vans is not entirely in line with Directive 2006/126/EC because category B 
driving licences do not allow the holders to drive these vehicles without applying for another 
type of licence. 

Further to that, the Department for transport in the UK indicated in their report265 that there is a 
new requirement for certain electrically assisted pedal cycles to obtain type approval.  

During the interviews, it was also indicated that there might be a need for alignment with the 
type approval legislation in case of the new light electric vehicles266.  

Also, in the interview two Members States said that there is a lack of an EU-wide standard for 
driving licences for agricultural vehicles267. 

5.4.6 

Impacts of observed inconsistencies / gaps / overlaps  

EQ  19  “What  are  the impacts  of  the  observed internal/external  inconsistencies/  gaps/overlaps  on the 

effectiveness 

The  evidence  on  the  possible  impact  of  inconsistencies  is  limited  and  some  conclusions  can 
only be drawn tentatively. The possible impacts identified were distortion of the internal market 
and  hindered  free  movement  caused  by  different  minimum  age  requirements  of  professional 
drivers  (in  the  meantime  clarified  by  the  new  Directive  (EU)  2018/645,  amending  Directive 
2003/59/EC  and  Directive  2006/126/EC),  difficulties  in  the  recognition  of  third  country 
professional drivers qualifications, difficulties in punishing cross-border traffic offences due to 
the  absence  of  the  mutual  recognition  of  driving  disqualifications,  lack  of  operability  of  the 

264   DK and the IFMC. 
265   Department  for  Transport  (2017),  Implementing  EU  Regulation  168/2013  on  type  approval  of  Motorcycles,  tricycles  and  quadricycles. 
https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/632874/motorcycles-consultations.pdf  

266   Interview with NL. 
267   BE and NL.  

69 

 
 
 
                                                           
provision on normal residence, non-promotion of environmentally-friendly vehicles, and a lack 
of social and technological progress in this area. 

A  few  examples  of  impacts  were  given  by  respondents  in  the  survey  with  non-governmental 
stakeholders  when  assessing  the  consistency/  gaps/  overlaps  with  other  legislation.  For 
instance, third country professional drivers encounter difficulties when their professional driver 
qualifications  are  not  recognised  due  to  the  inconsistencies  between  the  driving  licence 
directive and Directive 2003/59/EC. Additionally, professional drivers must wait until a certain 
age to acquire their driving licences which represents a barrier to access the profession.  

During the interviews, a few additional problems and their impacts were raised by  individual 
stakeholders268: 

  absence of mutual  recognition  of driving disqualifications may have an  adverse effect 

on road safety; 

  clarity  issues  related  to  normal  residence  may  impede  the  general  objective  of  free 

movement of EU citizens; 

 

the  directive  does  not  promote  the  use  of  environmentally-friendly  vehicles  and  the 
social and technological progress in this area. 

268   BE, DE, DK, FIA and the IFMC. 

70 

 
 
 
                                                           
5.5  EU Added Value  

This subsection assesses the added value delivered by or associated with the implementation of 
the  directive,  over  and  above  what  reasonably  could  have  been  expected  from  national  and 
regional policies and their implementation. 

Relevant questions to assess this objective 

EQ  20  What  are  the  benefits  of  intervening  at  EU  level,  over  and  above  what  could  have  been 
reasonably  expected  from  Member  States  acting  individually  at  regional,  national  or 
international level (notably through the UNECE structure)? 

EQ  21  How  much  actual  value  has  been  created,  and  what  evidence  is  there  in  terms  of  order  of 

magnitude of this added value?  

EQ 22 Would it have been possible to have the same results without the directive 

5.5.1  Benefits  of  intervening  at  EU  level  compared  to  acting  at  regional,  national  or 
international level  

through  bilateral  and 

The analysis indicates that the main benefit of intervening at EU level, compared to what could 
increased 
have  been  achieved 
harmonisation of driving licence rules and requirements. This had positive implications on road 
safety,  freedom  of  movement  of  EU  citizens,  reduction  in  fraud  and  driving  licence  tourism, 
and  reduced  administrative  burden  for  drivers  and  national  authorities.  Those  effects  would 
probably not have been as pronounced if they had been based solely on national legislation.  

international  cooperation,  was 

The implementation study  269 indicated that the directive has successfully harmonised rules on 
driving  licences  across  the  EU  Member  States,  facilitated  greater  freedom  of  movement, 
reduced  the  possibility  of  driving  licence  fraud,  and  has  generally  improved  road  safety.  The 
introduction of a single model of driving licence, the uniform approach towards driving licence 
categories,  the  mutual  recognition  of  driving  licences  and  harmonisation  of  administrative 
validity periods, have improved free movement of citizens and facilitated the reduction of fraud 
and  driving  licence  tourism.  RESPER  contributed  to  reducing  the  administrative  burden  of 
driving licence authorities, driving licence fraud, and driving licence tourism.  
This was confirmed by almost all interviewees (17 out 18), who indicated that there has been 
an  added  value  of  the  directive.270  The  respondents  in  the  survey  of  non-governmental 
stakeholders mostly agreed that the directive has had positive results in terms of free movement 

269   European Commission (2017), The implementation of Directive 2006/126/EC on driving licences. Report drafted by Hasselt University, 

NTUA. 

270   National  authorities:  BE,  BU,  DE,  ES,  FI,  GR,  NL  and  SI.  Non-governmental  stakeholders:  STR,  FEMA,  FIA,  IFMC,  IRU,  ACEM, 

CIECA, BVF and ETF. 

71 

 
 
 
 
 
                                                           
(34  out  of  36)271  and  road  safety  (30  out  of  36)272,  which  could  not  have  been  achieved  at 
national or local level (for more details please read also section 5.1.1.2 on “Free Movement and 
Annex  2  on  the  “Stakeholder  Consultation”).  Moreover,  the  statistical  analysis  provides  a 
quantification of the level of added value of EU intervention through the  directive. Compared 
to the baseline of no EU intervention – thus a scenario comprising only national legislation and 
regional  agreements  –  the  data  indicates  a  possible  reduction  up  to  7%  in  road  accident 
fatalities due to EU-level intervention.273 
The  objective  related  to  road  safety  has  been  supported  especially  by  the  provisions  on 
minimum requirements for examiners and medical checks for professional drivers. As regards 
the  progressive  access  to  higher  motorcycle  categories,  though  there  is  less  evidence  of  road 
safety  benefits  of  such  system,  it  still  seems  to  be  perceived  as  beneficial.  National 
authorities274 highlighted certain benefits related to the system of progressive access to category 
A  licences,  particularly  when  it  comes  to  road  safety,  due  to  increased  focus  on  training  and 
examination  through  the  staged  approach.  One  authority275  nevertheless  said  that  there  is  no 
evidence that the progressive access system contributed to better education, training curricula 
or road safety.  

Two interviewees acknowledged the added value of the provision on standardised examination 
requirements when it comes to road safety.276 One of the respondents indicated that the directive 
has established a better trust among the Member States277. 

As compared to other international frameworks (UN Conventions on Road Traffic) there is data 
to point to a higher level of added value for road safety emerging from the directive, due to the 
stricter rules and increased harmonisation. 

5.5.2  Added value created by the directive and results that could have been achieved without 
it  

The analysis indicates the EU value added of the directive. The quantitative assessment points 
to an annual reduction of 1.66% of road fatalities between 1983 and 1996 as compared to non-
Member  States  which  did  not  implement  the  directive,  and  in  which  an  annual  increase  of 
0.26% in road fatalities was observed after 1983. Although it is difficult to isolate the impacts 
of  the  directive  from  other  factors,  the  views  of  national  authorities,  both  in  the  survey  and 
interviews,  point  to  the  value  added  created  by  the  directive.  Non-governmental  stakeholders 
mostly agreed that the directive has achieved positive results in terms of free movement. 

271   5 automotive and motorcycle federations, 1 drivers association, 7 driving school associations, 10 road safety and road users' associations 

(or civil societies and their members), 1 vehicle manufacturer association, 10 'other category'. 

272   4 automotive and motorcycle federations, 1 drivers association, 6 driving school associations, 10 road safety and road users' associations 

(or civil societies and their members), 1 vehicle manufacturer association and 8 'other category'. 

273   See more details in section 2.2. 
274   SI, FI, GR, BG and DE. 
275   NL. 
276   FI and CIECA. 
277   FI. 

72 

 
 
 
                                                           
For analysis purposes after 1983 European countries were separated into two categories: those 
which  implemented  the  first  driving  licence  directive  80/1263/EEC  of  1980  and  those  which 
were not members of the EEC at that time and did not implement that directive, instead acting 
individually  at  regional  and  national  level.  For  the  Member  States  with  the  driving  licence 
directive  in  force,  an  annual  reduction  of  1.66%  in  fatality  rates  between  1983  and  1996  is 
observed. In non-Member States without the directive in force, an annual increase of 0.26% in 
fatality rates is observed after 1983. 

During  the  interviews,  6  out  of  7  national  authorities  and  7  out  of  9  non-governmental 
stakeholders indicated that it would have been difficult to achieve the same results278, without 
the directive.279 The interviewees mentioned several examples that would have prevailed in the 
absence of the directive, e.g. the administrative burden and the costs would have been higher, 
the  harmonisation  would  have  been  limited,  and  the  cooperation  between  the  EU  Member 
States would have been slower and more complex. 

In the survey with non-governmental stakeholders, most agreed that the directive has achieved 
positive results in terms  of free movement (34 out of 36)280 and road safety (30 out of 36)281 
which  could  not  have  been  achieved  to  the  same  extent  at  national  or  local  level.  Similar 
conclusions were obtained also as regards a reduction in the administrative burden for citizens 
and  national  authorities  and  as  regards  the  combat  against  driving  licence  fraud  and  driving 
licence  tourism,  which  24  out  of  36  respondents  found  was  better  achieved  through  the 
directive than it would have been through action solely at national or local level.  

Regarding  the  administrative  burden  and  cost  for  EU  citizens  and  driving  licence  authorities, 
there  is  more  doubt  as  to  whether  the  directive  led  to  positive  results  which  would  have  not 
been  possible  without  the  directive.  For  both  categories  (EU  citizens  and  authorities),  8 
respondents  disagreed,  however  the  majority  (16)  still  indicated  that  the  burden  and  cost  for 
citizens  and  driving  licence  authorities  have  been  reduced  due  to  the  directive,  and  that  this 
would have been possible with actions only at national and local level. Full details are available 
in Figure 2 in Annex 5. 

In terms of facilitating free movement, in the survey with non-governmental authorities, a few 
examples were given of EU Value added. For example, it was indicated that the administrative 
procedures  have  been  improved  due  to  the  EU  single  model  driving  licence,  which  is  for 
instance  relevant  when  travelling  in  Europe  and  being  involved  in  a  road  accident.  Other 
respondents  mentioned  that  the  directive  has  led  to  the  elimination  of  international  driving 
licence  red  tape,  and  made  it  easier  for  police  to  verify  validity  of  driving  licences.  Two 
respondents stated that the directive contributed to reduced costs and administrative burden for 
citizens when they move abroad. 

278   The harmonisation would have been limited (ES, BG, FI, GR, IRU, ACEM), the costs would have been higher (BU), the administrative 
burden  for  citizens  and  national  authorities  would  have  been  bigger  (BE,  ES),  the  cooperation  through  international  and  bilateral  fora 
would have been slower and much more complex (BE, FEMA, FIA) or completely impossible (SI), free movement would not have been 
facilitated (the NL, BG, GR) and the road safety level would have been lower (CIECA).  

279   National authorities: BE, NL, SI, FI, BG, ES; and non-governmental stakeholders: FEMA, IFMC, IRU, ACEM, CIECA, BVF, and FIA. 
280   5 automotive and motorcycle federations, 1 drivers association, 7 driving school associations, 10  road safety and road users' associations 

(or civil societies and their members), 1 vehicle manufacturer association, 10 'other category'. 

281   4 automotive and motorcycle federations, 1 drivers association, 6 driving school associations, 10 road safety and road users' associations 

(or civil societies and their members), 1 vehicle manufacturer association and 8 'other category'.  

73 

 
                                                           
In the open public consultation, the respondents mostly considered the benefits to be in the area 
of  freedom  of  movement  for  drivers  (almost  70%  of  the  respondents  reported  that  the 
improvements were  achieved to  a  great  or somewhat  extent), road safety for citizens (around 
60% of respondents indicated a great or somewhat extent), and the fight against driving licence 
fraud (almost 50% of replies indicated a great or somewhat extent).  

Furthermore, the majority of respondents indicated that the directive brought less benefits when 
it comes to  the equal  treatment  of non-professional  drivers. 50% of the  stakeholders  reported 
that improvements have been made in this area to a very little extent or not at all, as compared 
to  what  could  have  been  reasonably  expected  from  Member  States  acting  individually  at 
national  level,  whereas  less  than  30%  of  replies  considered  that  the  directive  has  had  an 
important role in this area.  

5.5.3   Would it have been possible to have the same results without the directive? 

The  analysis  assumes,  based  on  available  information,  that  in  the  absence  of  the  directive, 
Member States would probably have established more bilateral agreements with other countries 
or  groups  of  countries,  and  that  those  agreements  would  have  likely  not  reached  such  a 
comprehensive  harmonisation  of  driving  licence  rules  and  requirements  as  is  currently 
established by the directive. At the same time, Member States would likely have continued to 
rely on existing international mechanisms (i.e. through UNECE structures).  

When  comparing  the  achievements  of  the  directive  with  the  potential  accomplishments  that 
could have been achieved at regional, national, and international level in the absence of the EU 
directive,  the  key  added  value  of  the  directive  relates  to  increased  harmonisation  in  terms  of 
road  safety  and  free  movement.  This  has  been  described  in  a  more  detailed  manner  in  the 
baseline  analysis  (see  section  2.2),  and  under  the  effectiveness  evaluation  (see  section  5)  the 
introduction of minimum  standards and harmonised driving licence rules  and requirements  at 
EU level has brought about benefits that would otherwise likely not have been achieved to the 
same extent. 

In the absence of the directive, the majority of the Member States would have likely relied on 
the  United  Nations  road  safety  mechanisms.  Considering  the  scope  of  these  instruments,  one 
can reasonably conclude that the achievements in terms of free movement of citizens would not 
have  been  better  facilitated  at  international  level.  As  regards  the  international  cooperation 
through  the  existing  structures  within  the  United  Nations  systems,  the  achievements  can  be 
better  compared  in  terms  of  road  safety  trends  rather  than  facilitation  of  free  movement  of 
citizens.  Namely,  the  United  Nations  legal  instruments  on  road  safety  are  different  in  scope; 
their aim is not to facilitate free movement of citizens but rather to facilitate the recognition of 
driving  licences  when  driving  in  a  foreign  country  for  a  shorter  period.  Those  conventions 
facilitate the free movement of drivers in short term visits to certain countries, but they do not 
have  mechanisms  similar  to  the  directive  in  the  case  of  a  permanent  change  of  country  of 
residence.  The  directive  establishes  rules  to  facilitate  the  process  for  the  exchange, 

74 

 
 
 
replacement,  and  renewal  of  driving  licences  for  driving  licence  holders  that  transfer  their 
normal residence, while the United Nations legal instruments don’t have such mechanisms.  

When  comparing  the  achievements  in  terms  of  road  safety  between  the  EU/EEA  region  and 
other UNECE sub regions282, the analysis indicates, based on the road fatality figures, that there 
is a higher level of added value for road safety emerging from the directive due to the stricter 
rules and increased harmonisation. 

According  to  the  literature  review283,  the  total  number  of  fatalities  in  road  traffic  accidents 
decreased  between  2007  and  2017  by  almost  30%  in  the  UNECE  region.284  The  same  source 
emphasises an even more substantial  decrease for the UNECE sub-region comprising the EU 
Member States and EEA countries. Among the UNECE sub-regions, a relatively low decrease 
was  observed  in  North  America  (11%).  When  drawing  a  comparison  between  the  UNECE 
region  and  the  EU/EEA  sub-region,  which  is  governed  by  a  stricter  road  safety  framework 
under the directive, it can be concluded that the road safety trends in the EU/EEA sub-region 
are improving at a faster rate than globally and in the overall UNECE region. This development 
could  be  an  indication  of  the  impact  of  the  directive,  but  it  is  necessary  to  interpret  this 
conclusion carefully, as road traffic developments depend on many different factors, one of the 
most  prominent  ones  being  the  development  level  of  a  country.  On  the  other  hand,  a 
comparison between the two UNECE sub-regions with mostly high-income countries, namely 
the EU/EEA sub-region and North America, shows that the road safety trends based on the road 
fatalities indicator are substantially better in the EU/EEA sub-region.  

The  EU  added  value  is  also  evidenced  by  the  results  of  the  statistical  analysis  which  clearly 
show that the directive has led to improved road safety in the Member States. The trends have 
been  improving  faster  in  the  Member  States  than  in  the  non-Member  States  which  did  not 
implement the directive. 

Another  key  benefit  of  the  directive  as  compared  to  what  could  have  been  achieved  through 
bilateral  and  international  cooperation  is  increased  harmonisation.  This  was  confirmed  by  5 
interviewed national  authorities285, and 5 non-governmental stakeholders.286  This  was specially 
the case with: 

  The introduction of a single driving licence model (before the directive there were more 
than  110  different  driving  licence  models  with  different  entitlements  and  validity 
periods in Europe. The directive simplified this patchwork, reducing the administrative 
burden, and facilitating driver mobility.  

282   The UNECE region is governed by a set of international instruments which have some objectives which are similar to those in the driving 

licence directive. 

283   UNECE (2020), A foundational Safety System concept to make roads safer in the Decade 2021-2030. 

https://unece.org/DAM/road_Safety/Documents/4th_UN_Partnership_meeting_4_Nov_20/BN_UNECE_publication_road_safety_plan.pdf  
284   The ECE region covers the 56 countries that are UNECE Member States, including the countries of Europe, but also countries in North 
America (Canada and United States), Central Asia (Kazakhstan, Kyrgyzstan, Tajikistan, Turkmenistan and Uzbekistan) and Western Asia 
(Israel). 

285   BE, DE,ES, GR and NL. 

286   FEMA, FIA, IFMC, IRU, ETF. 

75 

 
                                                           
  The introduction of a uniform approach towards driving licence categories and validity 
periods:  this  has  improved  free  movement  of  citizens  and  facilitated  the  reduction  of 
fraud and 'driving licence tourism'.  

  Establishment  of  a  pan-European  network  for  the  exchange  information  on  driving 
licences (RESPER): The establishment of RESPER has made an important contribution 
to  reducing  the  administrative  burden  of  driving  licence  authorities  and  to  reducing 
'driving  licence  tourism'.Establishment  of  minimum 
driving  licence  fraud  and 
requirements for examiners. 

  Establishment of medical check-ups for professional drivers. 

 

Introduction of graduated access to motorcycle driving licences. 

76 

 
 
 
6.  CONCLUSIONS  

The evaluation has assessed the effectiveness, the efficiency, relevance, coherence and the EU 
added  value  of  Directive  2006/126/EC  on  driving  licences.  Based  on  the  analysis  in  the 
previous sections the following conclusions are drawn, while recalling the limitations detailed 
in section 4. 

Effectiveness   

Road Safety 

The analysis, as mentioned in section 4.2, faced limitations in terms of data availability, since 
there is no obligation of reporting applicable to the Member States under the directive. In that 
context,  unlike  other  policy  areas  subject  to  an  obligation  of  reporting,  there  is  no 
comprehensive  initial  set  of  data  available  for  the  analysis.  While  other  factors  have  also 
influenced  road  safety  (e.g.  improved  infrastructure,  education,  vehicle  technology,  reduced 
dangerous  behaviour),  the  analysis  provides  some  statistical  evidence,  with  the  respective 
caveats, that the effect of the directive has been positive when it comes to road safety. Although 
the  analysis  is  based  on  incomplete  data,  it  is  confirmed  by  stakeholders’  opinions  to  some 
extent. 

Certain new provisions of the directive are found by stakeholders to be particularly important in 
contributing  to  enhanced  road  safety,  including  minimum  standards  for  driving  examiners, 
medical examination for professional drivers, and tests for drivers of mopeds and motorcycles.   

While progress was likely made in terms of improving road safety, in light of the ambitious EU 
targets (Vision Zero and Valletta Declaration), more efforts are however needed to reduce road 
fatalities and accidents. The evaluation concludes that the directive could be an important tool 
that can contribute to this.  

Harmonisation of the driving licence rules 

A higher level of harmonisation of the driving licence rules across EU Member States seems to 
have been brought by the three driving licence directives of 1980, 1991 and 2006, and is likely 
to have been beneficial to the objectives on road safety and free movement. Nevertheless, some 
differences  still  remain  when  it  comes  to  administrative  validity  periods,  in  particular  the 
application  of  exemptions  for  certain  categories  of  drivers  (novice  drivers  and  older  drivers), 
the requirements for issuance of driving licences upon expiry of administrative validity periods, 
the  requirements  for  medical  checks  and  for  periodicity  of  medical  examinations  of  non-
professional drivers (categories A and B), the practices and requirements on training and testing 
(e.g.  formal,  informal,  or  combination  training,  hazard  perception  risk  /  self-assessment,  risk 
awareness,  self-awareness  requirements),  the  requirements  for  drivers’  examiners,  and  the 
recognition of driving licences issued by third countries.   

77 

 
 
 
 
 
Skills and knowledge 

Training  requirements  vary  considerably  across  Member  States,  while  the  standards  on  skills 
and  knowledge  of  drivers  are  established  by  the  directive.  There  is  limited  information 
concerning the extent to which the skills of professional and non-professional drivers may have 
improved  and  the  effect  the  directive  may  have  had  in  this  regard.  The  results  of  the 
consultation  activities  are  inconclusive  when  it  comes  to  the  direct  effect  of  the  directive  on 
raising  driving  skills.  Stakeholder  views  vary  regarding  the  need  to  harmonise  training 
obligations.  Some  stakeholders  indicate  that  the  absence  of  a  harmonised  framework  for 
training  has  implications  on  the  skills  of  drivers  and  road  safety,  whereas  other  stakeholders 
point  to  the  need  to  allow  flexibility  to  Member  States  to  accommodate  their  national 
specificities  in  defining  training  curricula.  At  the  same  time,  the  consulted  stakeholders 
highlight  the  importance  of  elements  such  as  risk  awareness  and  self-awareness  for  novice 
drivers and low mileage drivers when it comes to important aspects for ensuring road safety.  

In addition, the directive sets out minimum standards for driving examiners concerning quality 
assurance  and  regular  periodic  training  measures.  The  evaluation  finds  that  most287  Member 
States perceived that both quality assurance and periodic training requirements are sufficient to 
guarantee  quality  of  training  and  road  safety,  although  some  aspects  could  be  improved  (e.g. 
communication  skills).  Furthermore,  Member  States  and  non-governmental  stakeholders 
consulted  were  of  the  view  that  the  current  provisions  of  the  directive  concerning  drivers’ 
examiners have had a positive effect on road safety. 

Absence of an EU-wide framework for mutual recognition of driving disqualifications 

The  analysis  further  indicates  that  the  absence  of  an  EU-wide  framework  for  mutual 
recognition of driving disqualifications poses challenges when it comes to preventing abuse by 
drivers that commit traffic offences in one Member State but can then drive in another Member 
State  without  bearing  consequences  for  their  offences.  This  issue  was  also  raised  in  the 
proceedings of the European Court of Justice. 

RESPER 

RESPER  is  considered  an  effective  tool  for  the  exchange  of  information  between  national 
authorities. The advantages of RESPER include: fast exchange of driving licence information; 
access  to  relevant  information  on  validity  of  driving  licences;  possibility  to  prevent  driving 
licence fraud and accelerate the procedures related to exchange and renewal of driving licences; 
and facilitation of the implementation of the principle of mutual recognition of driving licences. 
The disadvantages relate both to the system's quality - query errors, incomplete information, as 
well  as  limited  uses.  RESPER  is  not  being  utilised  when  it  comes  to  exchange  of  driving 
information for enforcement purposes, exchange of information on demerit points, exchange of 
information on national codes, and normal residence.  

Facilitation of free movement 

Another key objective of the directive is the facilitation of the free movement of citizens inside 
the EU. The provisions that have  likely  been particularly impactful in  this regard include the 
Community  Model  driving  licence,  the  principle  of  mutual  recognition  of  licences  issued  in 
Member States, and minimum age categories.  

In contrast, other provisions presumably still result in administrative burden or obstacles to the 
free  movement  of  people.  This  is  the  case  of  the  provision  on  normal  residence,  which  has 

287   Desk research reveals that Member States considered that the current level of requirements for both quality assurance and periodic training 

are sufficient (19 out of 20 Member States). 

78 

 
                                                           
unexpected  negative  effects,  given  that  the  185  days  rule  is  difficult  to  apply  and  there  is  no 
clear definition for interpreting the existence of personal ties.  

While  there  is  limited  information  concerning  the  impact  of  differences  in  recognition  of 
driving  licences  issued  in  third  countries,  stakeholders  have  indicated  that  the  lack  of  a 
harmonised approach to recognising driving licences issued in third countries poses challenges. 
These include an increased administrative burden for authorities, driving licence shopping, and 
increased barriers for third country nationals, including professional drivers.  

Reduction of fraud and 'driving licence tourism' 

Reduction of fraud and 'driving licence tourism' has been another key objective of the directive. 
Although precise data on driving licence fraud and 'driving licence tourism' is not consistently 
available,  roughly  half  of  the  stakeholders  consulted  perceive  that  the  provisions  of  the 
directive particularly RESPER, the Union model, and anti-fraud measures, have contributed to 
reducing fraud and 'driving licence tourism’.  

Efficiency 

The  existing  evidence  does  not  allow  quantification  of  the  extent  to  which  the  directive  may 
have led to excessive costs or administrative burden for citizens, authorities and firms. On the 
one hand, the provisions on the Community Model driving licence and RESPER do not appear 
to  have  led  to  additional  costs  for  citizens  and  are  also  found  to  have  likely  contributed  to  a 
reduction  in  administrative  burden.  On  the  other  hand,  harmonised  validity  periods  and  the 
requirement to renew driving licences periodically, as well as the requirement to have regular 
medical  checks  for  professional  drivers,  are  found  to  have  likely  increased  administrative 
burden  and  costs  for  citizens.  Progressive  access  to  category  A  system  is  also  possibly 
associated with increased costs and burden on applicants. 

Significant  differences  are  found  in  the  driving  licence  fees  incurred  in  Member  States.  The 
main  causes  for  variation  in  costs  are  related  to  national  requirements  and  the  level  of 
efficiency  and  organisational  specificities  of  national  administrations.  Similar  differences  are 
found  in  the  training  costs  incurred  in  the  Member  States.  These  may  be  explained  by 
differences  in  training  requirements  in  terms  of  the  number  of  lessons  (theoretical  and 
practical), requirements for specialised training (e.g. cost of first aid course), and the national 
and regional specificities in terms of the market for the provision of driving licence training. 

Several  areas  with  potential  for  simplification  and  reduction  of  administrative  burden  are 
identified. These relate to: digital licence renewal and medical checks for professional drivers; 
progressive access to category A licences; rules related to weight limits for category B licences; 
and  processes  related  to  normal  residence.  Digital  solutions  and  digitalisation  of  driving 
licences  are  insufficiently  explored  at  present,  and  the  use  of  RESPER  could  offer  further 
potential for reduction in the administrative burden.  

Relevance 

The  technological  context  for  driving  licences  has  evolved  over  the  past  years  due  to 
digitalisation,  new  technological  solutions,  and  increased  awareness  about  the  environmental 
impact of the transport sector. The evaluation finds that the current provisions of the directive 
on  driving  skills  and  knowledge  do  not  sufficiently  reflect  the  new  technological  solutions, 

79 

 
 
 
 
 
such as semi-automated and automated driving, vehicles with automatic transmission, advanced 
driver-assistance  and  efficiency  increase  systems,  and  alternative  fuel  vehicles.  Furthermore, 
digital transformation provides an opportunity to further improve document security based on 
digital counter-falsification measures and requires the mutual recognition of driving licences to 
be extended to digital driving licences.   

New transport modes, offering new solutions of micro-mobility such as electric scooters, bikes 
and  mopeds,  have  increased  in  popularity  among  road  users.  However,  currently  Member 
States have different approaches to regulating such new forms micro-mobility. Some consulted 
stakeholders  have  raised  concerns  related  to  the  absence  of  a  common  EU  framework  for 
regulating  new  micro-mobility  solutions,  in  particular  when  it  comes  to  road  safety.  Others, 
however, doubt the need for an EU initiative on micro-mobility. 

The evaluation finds that there may be a need to maintain a balance between road safety and 
the  mobility  needs  of  young  drivers.  The  current  minimum  age  limits  established  by  the 
directive are found to be broadly adequate. However, there is substantive variation in minimum 
age  limits  amongst  countries,  in  particular  as  regards  licences  for  mopeds.  The  consultation 
also pointed to the fact that stakeholders representing the motorcycling community consider the 
system of progressive access and requirements thereof to be too demanding for young people. 
Some  Member  States  have  explored  the  potential  to  lower  the  minimum  age  limit  for 
accompanied  driving  for  non-professional  drivers  and  professional  drivers.  Regarding  age 
limits  for  professional  drivers,  there  is  no  unanimous  view  amongst  stakeholders  as  to  the 
appropriate age limits. While trade union representatives broadly indicate that there is no need 
to lower the minimum age and efforts should focus on the attractiveness of the sector, industry 
representatives point to the need to lower the age requirements to address the problem of driver 
shortages in Europe. 

The analysis points to the fact that a balance may also need to be achieved between road safety 
and  the  mobility  needs  of  ageing  drivers.  Member  States  have  taken  different  approaches  in 
terms  of  regulating  the  mobility  of  older  drivers  with  several  Member  States  implementing 
special  requirements  for  older  drivers  (e.g.  increased  medical  checks,  shorter  validity  periods 
upon  renewal).  There  is  no  conclusive  evidence  that  fitness  screening  based  on  age  provide 
significant safety benefits288 but the consultation indicates that more attention should be paid to 
high health risk drivers and the consultation indicates that more attention should be paid to high 
health  risk  drivers.  Another  conclusion  of  the  evaluation  is  that  the  increased  mobility  of 
citizens  within  the  EU  is  causing  difficulties  in  obtaining  a  driving  licence  in  instances  of 
insufficient command of the official language of the country of residence. 

Coherence 

The  evaluation  found  no  major  internal  inconsistencies  between  the  directive's  provisions. 
However, a key area where further precision may be needed relates to the provisions on normal 
residence,  which  pose  challenges  signalled  by  national  authorities.  Inconsistencies  regarding 
equivalence  rules  were  also  raised,  and  the  level  of  precision  of  Annex  III  on  standards  on 
alcohol and drugs and medicinal products was regarded as being insufficient. 

In  terms  of  coherence  with  international  legislation,  the  evaluation  did  not  find  major 
inconsistencies between the directive and the international conventions with similar objectives 
(1949 Geneva Convention on Road Traffic and the 1968 Vienna Convention on Road Traffic).   

288   Study on driver training, testing and medical fitness (2017) 

80 

 
 
                                                           
In terms of coherence with EU road safety and transport legislation, the evaluation finds overall 
coherence  with  overarching  EU  policies  (e.g.  Vision  Zero,  Valletta  Declaration)  and  EU 
legislation.  The  directive  is  found  to  be  complementary  to  the  Cross-Border  Enforcement 
directive  2015/645,  but  synergies  seem  to  be  insufficiently  explored  concerning  the 
enforcement of mutual  recognition of driving disqualifications between countries.  In terms of 
coherence  with  other  EU  legislation,  the  evaluation  does  not  point  out  to  major  gaps  or 
inconsistencies.  However,  the  directive  is  not  sufficiently  aligned  with  the  type  approval 
legislation  in  particular  Regulation  (EU)  No  168/2013  (L-category  type  approval  framework, 
and the possibility to tow trailers with category A vehicles).  

EU added value 

The evaluation concludes that the main benefit of the directive as compared to what could have 
been  achieved  in  bilateral  and  international  cooperation  is  related  to  the  increased 
harmonisation  of  driving  licence  rules  across  Member  States.  The  analysis  indicates  that  the 
directive  has  had  a  positive  effect  on  road  safety,  the  free  movement  of  EU  citizens,  the 
reduction  in  driving  licence  fraud  and  driving  licence  tourism,  as  well  as  reduction  in 
administrative burden. However, some challenges remain regarding some provisions. The same 
level  of  achievement  would  probably  not  have  occurred  in  the  absence  of  the  directive,  as 
cooperation would have likely continued via bilateral agreements between countries which, in 
turn,  would  have  also  probably  implied  a  higher  complexity  of  the  licensing  system  and  a 
greater administrative burden.  

81 

 
 
 
 
  ANNEXES  

  Annex 1: Procedural information 
  Annex 2: Summary of public and stakeholder consultation  
  Annex 3: Methodology 
  Annex 4: Intervention logic  
  Annex 5: Tables and graphs 
  Annex 6: REFIT costs and benefits 

82 

 
 
 
Annex 1: Procedural information 

 1. LEAD DG, DeCIDE PLANNING  

• The lead Directorate-General is DG MOVE.  

• The evaluation was validated in Decide under reference PLAN/2019/5793 

 2. ORGANISATION AND TIMING  

• The evaluation roadmap was published on 13 August 2019.  

•  The  evaluation  was  launched  on  24  October  2019  with  the  first  meeting  of  the  Interservice 
Steering  Group,  consisting  of  the  following  Commission  Services  and  Agencies:  GROW,  EMPL 
MOVE,  SG,  SJ  and  RTD.  The  group  discussed  the  outline  of  the  evaluation,  including  the 
evaluation  roadmap  and  the  drafts  of  the  intervention  logic,  evaluation  questions,  consultation 
strategy and the terms of reference for an external study to support the evaluation.  

•  The  Commission  contracted  an  external  consultant  to  carry  out  the  study  to  support  the 
evaluation. This work started in March 2020 and was concluded on 30 March 2021. The kick-off 
meeting for the support study was held on 20 March 2020. 

• The Interservice Steering Group discussed the inception report for the support study on 20 March 
2019.  

•  On  16  October  2020,  a  stakeholder  workshop  was  held  to  present  preliminary  results  of  the 
evaluation and to consult with the more than 66 participants from the road safety sector. The results 
from the workshop were reflected in the evaluation and the support study.  

•  The  second  interim  report289  for  the  support  study  was  submitted  to  the  Interservice  Steering 
Group on 03 December 2020 and approved on 11 December 2020.  

• The Commission conducted a public consultation on the evaluation from 28 October 2020 to 20 
January 2021. 

•  The  Interservice  Steering  Group  discussed  the  draft  final  report  for  the  support  study  on  19 
February 2021. All final deliverables of the support study, including the final report, the executive 
summary, all technical annexes and the stakeholder consultation report were approved on 22 June 
2021.  

. EVIDENCE, SOURCES AND QUALITY  

• The evaluation relies mostly on the support study in the ex post evaluation290conducted by an 
external contractor.  

• This study will be publicly available. 

289 Which included the results of the first interim report. 
290 Support Study to the ex-post evaluation of Directive 2006/126/EC on Driving Licences (Specific Contract MOVE/C2/2019-534/SI2.826438 

under framework contract MOVE/A3/2017-257) - ISBN: 978-92-76-37815-0 

83 

 
 
                                                           
Annex 2: Stakeholder consultation 

INTRODUCTION 

The  Commission  coordinated  various  consultation  activities  between  13  August  2019  and  20 
January 2021 in the context of the ex-post evaluation of the directive. 

The  Commission  conducted  one  consultation  on  the  roadmap  of  the  initiative,  and  one  open 
public  consultation291.  Exchanges  were  also  held  during  meetings  of  expert  groups  and 
Committees chaired by the Commission. 

The  Commission  also  contracted  an  external  study  in  support  of  the  evaluation.  The  study 
included targeted questionnaires and interviews as well as a workshop — all conducted by the 
contractor292. Their results are also included in this report. 

CONSULTATION METHODS 

In  order  to  ensure  that  all  affected  and  interested  stakeholders  are  represented  during  the 
stakeholder  consultation,  the  approach  for  consulting  stakeholders  and  citizens  has  been 
presented in the roadmap of the initiative.  

The  roadmap  was  published  on  13  August  2019,  and  was  then  open  for  feedback  until  10 
September 2019. 

Targeted surveys were conducted with national authorities and non-governmental stakeholders 
between 31 August and 11 December 2020.  

Structured  interviews  with  national  authorities  and  non-governmental  stakeholders  were  also 
conducted between 4 May and 24 August 2020. 

A  stakeholder  workshop  was  conducted  on  16  October  2020  for  the  purpose  of  gathering 
evidence,  confirming  identified  findings,  seeking  feedback  on  emerging  findings,  and 
collecting views.  

Finally,  an  open  public  consultation  was  also  held  between  28  October  2020  and  20  January 
2021,  allowing  the  interested  public  and  stakeholders  to  express  their  views  on  the  current 
rules. 

TARGETED CONSULTATION  

The targeted consultation involved surveys and interviews conducted on a number of selected 
stakeholders,  as  opposed to  the public consultation and the roadmap, which were open to  the 
public. 

291   The details of the consultations can be consulted at https://ec.europa.eu/info/law/better-regulation/have-your-say/initiatives/11930-Driving-

licence-rules-evaluation_en  

292   “Support  study  to  the  ex-post  evaluation  of  Directive  2006/126/EC  on  driving  licences”  by  COWI  commissioned  by  the  European 

Commission 

84 

 
                                                           
SURVEYS 

Targeted surveys with national authorities and non-governmental stakeholders were held from 
31 August until 11 December 2020.  

The  questionnaire  for  national  authorities  was  answered  by  national  authorities  (ministries, 
national transport authorities) covering 26 Member States(Austria, Belgium, Bulgaria, Croatia, 
Cyprus,  Czechia  ,  Denmark,  Estonia,  Finland,  France,  Germany,  Greece,  Hungary,  Ireland, 
Italy,  Latvia,  Lithuania,  Luxembourg,  Malta,  Netherlands,  Portugal,  Romania,  Slovakia, 
Slovenia,  Spain,  Sweden).  In  two  cases  (i.e.  Luxembourg  and  Bulgaria),  2  different  national 
authorities from the same country provided answers to the questionnaire. Furthermore, national 
authorities  from  covering  2  EEA  countries  (Iceland  and,  Norway)  and  Switzerland  also 
provided  responses  to  the  questionnaire:  The  results  of  the  survey  are  comprehensive  in  the 
sense that they cover all Member States. The majority of the questions addressed to the national 
authorities concerned the collection of objective information related to the policy options made 
by the directive and the level of implementation of its provisions.  

The  questionnaire  for  non-governmental  stakeholders  was  answered  by  41  participants 
covering  various  stakeholder  categories  e.g.  road  safety  and  road  users’  associations,  driving 
school associations, drivers’ associations, automotive and motorcycle federations, international 
road transport associations and vehicle manufacturer associations, as illustrated below. 

Figure 1 – Distribution of non-governmental organisations having answered to the survey by type 

Source: Survey with non-governmental organisations. 

STRUCTURED INTERVIEWS 

A series of interviews have been held with 9 national authorities (Belgium, Bulgaria, Denmark, 
Finland,  Germany,  Greece,  Netherlands,  Slovenia  and  Spain)  and  13  non-governmental 
stakeholders 
road  safety 
organisations,  driving  schools,  transport  workers,  motorcyclists,  motor  homes’  owners,  and 
road transport operators).   

(motorcycle  and  automotive 

industry,  driving 

instructors, 

85 

 
 
 
STAKEHOLDER WORKSHOP 

A  stakeholder  workshop  was  conducted  on  16  October  2020  with  the  purpose  of  gathering 
evidence, confirming issues found in the evaluation, collecting views on the performance and 
implementation of the directive, and seeking feedback on the emerging findings. The workshop 
was  aimed  at  the  validation  and  discussion  of  preliminary  findings  with  the  stakeholder 
community.  Itwas  attended  by  66  participants  including  representatives  from  driving  licence 
authorities,  transport  safety  associations,  road  user  associations,  driving  schools  associations 
and  driving  schools,  automotive  and  motorcycle  federations,  the  consortium  members  of  the 
support study and policy officers of the European Commission. 

OPEN PUBLIC CONSULTATION 

An  open  public  consultation  was  also  carried  out,  between  28  October  2020  and  20  January 
2021,  when  a  total  of  546293  respondents  from  23  Member  States  and  8  other  countries 
provided  feedback.  An  absolute  majority,  i.e.  57%  (313),  of  respondents  originated  from  the 
Netherlands, followed by Belgium (10%), Sweden (5%), and Germany (3%). Eastern European 
countries were less represented. The high proportion of respondents from the Netherlands can 
be explained by a wide mobilisation to provide views concerning motorcyclist rules.  

Figure 2 Distribution of respondents by country of origin (N= 546) 

Source: Open Public Consultation, Question: Country of origin 

The  majority  of  respondents  (77%,  i.e.  422  respondents)  answered  as  EU  citizens.  A  high 
percentage of EU citizens originated from the Netherlands (71% of respondents that identified 
themselves  as  EU  citizens).  The  remainder  of  the  respondents  represented  a  variety  of 
stakeholder  groups  including  business  associations,  companies  /  business,  non-governmental 

293   548 responses were received but 2 were excluded from analysis as they indicated that they were tests. 

86 

 
 
                                                           
organisations,  public  authorities,  trade  unions,  consumer  organisations,  non-EU  citizens  and 
academic institutions. 

Figure 2 

Distribution of respondents by type of stakeholder (N= 546) 

Source: Open Public Consultation Survey, Question: I am giving my contribution as … 

EVALUATION ROADMAP CONSULTATION 

A  consultation  on  the  evaluation  roadmap  was  held  during  the  period  13  August  2019  to  10 
September  2019.  Comments  were  provided  by  22  respondents.  The  consultation  responses 
included: 10 business associations; 3 non-governmental organisation; 2 business organisations / 
businesses;  1  public  authority;  3  consumer  organisations;  1  other  association  (optometry  and 
optics); and 2 EU citizens.  

GENERAL AREAS OF INTEREST FOR NON-GOVERNMENTAL STAKEHOLDERS 

Each of the major stakeholder groups addressed have certain areas of particular interest in the 
evaluation. Road safety and road users associations have a particular interest when it comes to 
the  provisions  of  the  directive  and  the  extent  to  which  they  yield  the  best  results  in  terms  of 
road  safety.  Driving  school  associations  have  a  specific  interest  in  the  provisions  on  training 
and testing of drivers. Drivers’ associations have an interest in ensuring that the provisions of 
the directive do not impose unnecessary burden and provide for a smooth process of obtaining 
a licence and related procedures. International and road transport associations have a particular 
interest  when  it  comes  to  road  safety,  as  well  as  specific  provisions  of  the  directive  such  as 
provisions  concerning  professional  drivers  and  provisions  concerning  motorcycle  riders. 
Finally,  automotive  and  motorcycle  federations  and  vehicle  manufacturer  associations  have  a 
particular  interest  in  ensuring  that  the  provisions  of  the  directive  do  not  negatively  affect 
technological advances in the industry. 

87 

 
 
 
CONSULTATION RESULTS  

Impact on Road Safety 

Most  of  the  respondents  who  could  make  an  assessment  in  the  survey  of  national  authorities 
(11 out of 32 ), most non-governmental survey respondents (30 out of 41), national authority 
interviewees (9) and non-governmental stakeholder interviewees (7 out of 13) made a positive 
assessment  of  the  contribution  that  the  directive  has  had  on  road  safety.  Furthermore,  open 
public consultation respondents (362 out of 546) generally assess the directive as having had a 
positive effect on road safety. Below we present some of the more detailed results. 

In your view, to what extent is the directive a relevant tool to reduce the number of road crashes in the EU?  

Source: Open Public Consultation Survey, Question 1. 

When analysing the results by stakeholder group, it is notable that most of the stakeholders that 
considered the directive had not been a relevant tool to reduce road safety were represented by 
EU citizens (i.e. 90%, i.e. 126 of the 140 respondents that had either answered 'very little' or 
'not at all' were EU citizens).  

In your view, to what extent is the directive a relevant tool to reduce the number of road crashes in the EU?  

Source: Open Public Consultation Survey, Question 1. 

88 

 
 
 
 
 
 
 
 
 
 
 
 
Particularly important provisions  

Provisions that are considered to have been particularly important by stakeholders when it 
comes  to  road  safety  include  minimum  standards  for  driving  examiners  (including  quality 
assurance and periodic training), medical examinations for professional drivers, and training for 
drivers.  The  positive  impact  on  drivers  is  also  echoed  by  driving  school  associations.  In  the 
targeted survey with non-governmental stakeholders the following opinions where expressed: 

How important are the following provisions of 
the driving licence Directive 2006/126/EC in 
improving road safety 

How important are the following provisions of the 
driving licence Directive 2006/126/EC in ensuring 
free movement of EU citizens? 

Source: targeted survey with non-governmental stakeholders 

Free Movement 

The  stakeholders  consulted  (23  out  of  32  respondents  in  the  survey  of  national  authorities,  9 
national  authorities  interviewed,  and  8  out  of  13  non-governmental  stakeholder  interviews) 
indicate that the  directive facilitated free movement  of persons. The open public consultation 
also pointed to the fact that the directive has contributed to facilitating free movement of both 
professional  (378  out  of  546  respondents)  and  non-professional  drivers  (343  out  of  564 
respondents).  Some  of  the  more  detailed  results  of  the  open  public  consultation  are  set  out 
below: 

89 

 
 
 
 
 
 
To what extent do you think the directive is a relevant tool to facilitate the free movement of citizens when they 
drive across the EU, when driving non-professionally and when driving professionally?  

Source: Open Public Consultation Survey, Question 2. 

When looking at the distribution of responses by type of stakeholders, less positive assessments 
of  the  relevance  of  the  directive  as  a  tool  to  facilitate  free  movement  of  citizens  came  again 
from  respondents  that represented EU  citizens as well as non-EU citizens (see figure  below).

To what extent do you think the directive is a relevant tool to facilitate the free movement of citizens when they 
drive across the EU, when driving non-professionally and when driving professionally?  

When driving non-professionally 

When driving professionally 

However  it  is  generally  recognised  that  certain  provisions  of  the  driving  licence  directive 
negatively affect the free movement of drivers, particularly the rules on normal residence. 

90 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
CONSULTATION RESULTS – ADMINISTRATIVE BURDEN ON CITIZENS 

Consulted stakeholders presented mixed views when it comes to the new procedures introduced 
by the third driving licence directive.  

On one hand, their views were either neutral on the effect - 14 out of 20 national authorities in 
the targeted survey said that the processing time had not changed after the directive - or broadly 
positive  -  in  the  range  of  9  to  15  respondents  (see  graph  bellow)  in  the  targeted  survey  with 
non-governmental authorities assessed that the procedures for first issue, replacement, renewal 
or exchange have become less complex and costly. 

To what extent do you agree with the following statements concerning the impacts of the directive for EU 

citizens since it was first time implemented (1983)? (N=37) 

Source: Survey with non-governmental organisations. 

On the other hand, interviewed stakeholders (7 out of 9 interviewed national authorities, 9 out 
of 13 interviewed non-governmental stakeholders) as well as the open public consultation (196 
out of 546 respondents) point to the fact that the administrative validity periods rules have led 
to  higher administrative burden, particularly when it comes to  professional  drivers. However, 
some stakeholders (5 out of 13 interviewed national authorities) have also acknowledged that 
the  benefits  of  the  harmonisation  outweigh  the  burden.  In  the  open  public  consultation,  the 
following questions were asked relating to the effect on administrative burden: 

91 

 
 
 
 
 
Impact of introducing a 5-years validity period on the driving licences of professional 
drivers? 

For professional drivers with activities in other Member States 

For professional drivers with only national activities 

Source: Open Public Consultation Survey, Question 9. 

In the comparison of the situation between 2000 and 2013 and the current one, respondents to 
the  public  consultation  saw  a  positive  improvement  overall.  Most  of  all,  respondents  agreed 
that it has become easier for professional drivers to operate in other Member States thanks to 
mutual  recognition  of  driving  licences.  58%  of  all  respondents  (i.e.  318)  agreed  or  strongly 
agreed with this statement. Respondents also pointed to improvements as regards the decrease 
in  administrative  burden  when  travelling  by  road  through  another  Member  State.  52%  of 
respondents  either  agreed  or  strongly  agreed  that  travelling  has  become  less  burdensome. 
Furthermore, 41% agreed or strongly agreed that the directive is effective with regard to mutual 
recognition of driving licences and its impact on professional drivers, whereas 12% disagreed 
or strongly disagreed with this statement. 

Comparing the current situation with the situation between 2000 and 2013, what is your opinion on the 
following statements?  

92 

 
 
 
 
Source: Open Public Consultation Survey, Question 10. 

As regards the results across various stakeholder groups( has shown in the chart below), it can 
be observed that trade union representatives most strongly agreed that the mutual recognition of 
driving licences has made it easier for professional drivers to operate in other Member States. 
Furthermore,  this  stakeholder  group  almost  uniformly  disagreed  with  the  statement  that  the 
directive has been successful in relation to driving licence fraud. As regards the latter, around 
38% of public authorities shared the same view. 

The mutual recognition of driving licences has made it easier for professional drivers to 
operate in other Member States. 

CONSULTATION RESULTS – EFFECTS OF THE DIRECTIVE ON DRIVING SKILLS 

Concerning  the  skills  of  non-professional  drivers,  a  significant  proportion  of  national 
authorities  consulted  in  the  targeted  survey  (15  out  of  32)  provided  a  positive  assessment  on 
this  matter,  while  the  remainder  did  not  make  any  assessment.  Concerning  the  skills  of 

93 

 
 
 
 
professional drivers, a substantive proportion of national authorities consulted in the survey (18 
out of 32) could not make an assessment, whereas the remainder (13 out of 32) made a positive 
assessment. 

Has the  third  driving  licence  directive contributed to improving driving skills of non-professional drivers and 

professional drivers?  

Source: Survey with national authorities. 

In the targeted survey with non-governmental organisations, just over a half of the 41 surveyed 
stakeholders perceived that the directive led to improved driving skills of professional and non-
professional drivers 

CONSULTATION RESULTS – EFFECT OF THE DIRECTIVE ON EXAMINERS’ SKILLS 

National  authorities  consider 
to  knowledge  and 
understanding of driving and assessment, assessment skills, personal driving skills and quality 
of services is sufficient (19 out of 20 Member States). 

level  competences  related 

that 

the 

In  addition,  literature  review  indicates  that  national  authorities  generally  perceive  that  the 
current  provisions  of  the  directive  on  driving  examiners  have  had  a  positive  effect  on  road 
safety (11 out of 20 Member States).  

CONSULTATION RESULTS – EFFECT OF THE DIRECTIVE ON NOVICE DRIVERS 

23  out  of  32  respondents  in  the  targeted  survey  of  national  authorities,  and  9  national 
authorities interviewed,  pointed out that the directive has contributed to improved road safety 
by reducing the number of road fatalities and serious injuries at national  level for novice and 
young drivers. 

Almost  all  the  non-governmental  stakeholders  interviewed  had  the  same  view,  except  one 
which considers that the graduated access scheme applied to motorcycles is counterproductive 
because it reduces the number of young riders and therefore only delays the problem. 

94 

 
 
 
 
The  majority  of  respondents  to  the  open  consultation  (276  out  of  546)  strongly  disagreed  or 
disagreed that the graduated access system for motorcycle licences is important to ensure road 
safety, while only 184 either strongly agreed or agreed with the statement.  

However, it should be underlined  that a large proportion of these  negative answers  was from 
Dutch  stakeholders  (209  out  of  the  276).  Those  who  are  against  graduated  access  system  for 
motorcycle  licences  view  it  as  too  burdensome  for  novice  drivers,  while  other  stakeholders 
mainly  licensing  authorities,  consider  that  graduated  access  has  advantages  allowing  younger 
drivers to get familiar with less powerful bikes, before acceding the more powerful ones. 

Adequacy of the directive in relation to new technologies and new vehicles: 

In  the  open  public  consultation,  opinions  were  split  on  the  adequacy  of  the  directive  in 
relation to new technologies and new vehicles: 

To what extent are the knowledge requirements to obtain a driving licence adapted to new technologies fitted to 

vehicles? 

Source: Open Public Consultation Survey, Question 3. 

95 

 
 
 
 
As shown below, opinions were split across the various types of stakeholders. Notably, a large 
proportion of EU citizens, NGOs and trade unions considered the driving licence requirements 
to be very little or not at all adapted to new technologies.  

To what extent are the knowledge requirements to obtain a driving licence adapted to new technologies fitted to 

vehicles?  

To what extent do you agree with the following statements on current and future needs in terms of legal, social, and 
technological considerations and developments? The directive sufficiently covers the new mobility solutions such as e-scooters 
and other personal micro mobility solutions. (N=36) 

Source: Survey with non-governmental stakeholders.  

USE OF THE STAKEHOLDER INPUT FOR THE EVALUATION 

Stakeholder input received during the stakeholder consultation was an important tool to address 
certain limitations in access to quantitative data for the evaluation. The results from the analysis 
of the stakeholder input have been used when answering the individual evaluation questions as 
a  complementary  source  that  may  or  may  not  corroborate  the  findings  from  other  sources. 
Statements or positions brought forward by certain stakeholders have been highlighted as such.  

96 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Annex 3: Methodology 

(1) 

Methodology and sources of information 

The evaluation process started in August 2019, following the Commission’s Better Regulation 
Guidelines.294 In the Commission, an Inter-Service Steering Group (ISSG) provided advice and 
monitored  the  progress  of  the  exercise.  Being  composed  of  members  from  different 
Commission  services  and  having  the  necessary  mix  of  knowledge  and  experience,  the  ISSG 
brought  together  a  range  of  different  perspectives  and  provided  the  necessary  input,  in 
particular  where  the  evaluation  touched  different  policy  areas,  such  as  the  need  to  consider 
micro mobility solutions at EU level.  

A support study was carried out by an external contractor to provide input to this evaluation.295 
In  accordance  with  the  Terms  of  Reference,  the  study  was  structured  along  seven  tasks,  as 
depicted in the figure below. 

Figure 4 Support Study Methodology Structure 

294   https://ec.europa.eu/info/law/law-making-process/planning-and-proposing-law/better-regulation-why-and-how/better-regulation-

guidelines-and-toolbox_en 

295   Support  Study  to  the  ex-post  evaluation  of  Directive  2006/126/EC  on  Driving  Licences  (Specific  Contract  MOVE/C2/2019-

534/SI2.826438 under framework contract MOVE/A3/2017-257) - ISBN: 978-92-76-37815-0 

97 

 
 
 
                                                           
 
The methods and tools used for the evaluation are summarised in the following paragraphs.  

Review of legislative documents and reports 

In  order  to  provide  the  evaluation  with  factual  information,  desk  research  on  several  related 
issues  was  carried  out.  The  aim  of  the  desk  research  was  to  collect,  organise  and  analyse 
relevant information from relevant secondary sources. This included statistical data, legislative 
documents, and relevant reports and studies, with the intention of collecting both quantitative 
and qualitative evidence to complement the primary evidence collected through field research.  
All findings and results were compared and synthesised to provide evidence-based answers to 
the evaluation questions. 

The  analysis  was  structured  according  to  an  evaluation  matrix,  presented  in  Annex  3.  This 
matrix  operationalised  a  set  of  evaluation  questions  and  sub-questions,  indicators  and 
judgement criteria that would be used to answer them. It was developed on the basis of an in-
depth understanding of the directive’s intervention logic, taking in consideration what it aimed 
to achieve and how, as presented in Annex 4. 

Analysis of statistical data and modelling 

An analysis was conducted in order to examine and quantify wherever possible the effect of the 
driving licence directives on road safety (EQ 1, EQ 2.6). The findings rely on a comprehensive 
analysis of data on road safety indicators (the number of road fatalities is the basic road safety 
indicator)  collected  from  relevant  databases  (CARE  Database,  CADaS  Database,  IRTAD 
Database, EU Pocketbook). Along with the road safety data, population, vehicle fleet, vehicle 
kms, GDP and infrastructure data (length of motorways) were all collected from Eurostat and 
other  EU  sources  (CARE  Database296,  CADaS  Database297  and  IRTAD  Database298).  The 
different  time  periods  selected  to  analyse  the  impact  of  the  driving  licence  directive  by 
quantifying, wherever feasible, specific indicators, are presented below. 

-  Before 1983: no driving licence directive in place. 

-  From 1983 until now: full period of the driving licence directives in place: 

o  1983-1996: Time period with the first driving licence directive in force 

o  1996-2006: Time period with the second driving licence directive in force 

o  2007-2012: Implementation period of the third driving licence directive 

o  2013-2018: Time period with the third driving licence directive fully in force 

The methodological approach for the analysis includes five steps: four descriptive-exploratory 
steps and one statistical modelling step. 

296   Community Road Accident Database. 

297   CADaS - The Common Accident Data Set (D 1.14) is a common structure including a minimum set of standardised data elements. 

298   International Road Traffic and Accident Database (IRTAD) includes safety and traffic data, aggregated by country and year, from 1970 

onwards. 

98 

 
 
                                                           
Step 1 entailed a comparison of the total fatality trends before and after the first driving licence 
directive. 

Step  2  represented  a  comparison  of  the  total  fatality  trends  after  the  first  driving  licence 
directive between (i) the Member States with the driving licence directive in force and (ii) the 
European countries without the driving licence directive in force. 

Step  3  compared  the  total  fatality  trends  between  the  first,  second  and  third  driving  licence 
directives. 

For  these  first  3  steps,  a  descriptive  analysis  was  carried  out  to  analyse  total  road  accident 
fatality data from 1970-2018. The results of this analysis are presented as part of EQ 1. 

Step  4  constituted  a  comparison  between  the  fatality  trends  of  several  road  users  (directly 
affected  by  the  driving  licence  directive)  with  those  who  were  not  directly  affected,  for  the 
years 1999-2018 (due to limited data). The fourth step is based on examining the fatality trends 
of  the  following  road  user  groups  directly  affected  by  the  directive:  novice  drivers  due  to 
changes to harmonised rules on driving examiners and better training; motorcyclists and moped 
riders  due  to  modifications  of  driving  licence  categories  and  especially  the  graduated  access 
system for motorcycles starting from the new AM category. 

Step 4 also contains a descriptive analysis, which is presented in EQ2.6 and is a step prior to 
the modelling step which follows. 

Step  5  involved  the  development  of  7  statistical  models  (Generalised  Linear  Mixed  Models) 
which use panel  data for all available European  countries in  order to  predict the direct  effect 
(inferring causality) of the driving licence directive and other factors on road safety in Europe, 
and  more  specifically  on:  Total  Road  Accident  Fatalities  per  million  population;  Driver 
Fatalities  per  million  population;  Novice  Driver  Fatalities  per  million  population;  Elderly 
Driver Fatalities per million population; Professional Driver Fatalities per million population, 
PTW  Fatalities  (Mopeds  +  Motorcyclists)  per  million  population;  Motorcyclist  Fatalities  per 
million population. 

For  Step  5,  the  methodological  approach  relies  on  quantifying  the  impact  that  the  driving 
licence  directives  have  had  on  the  seven  (7)  target  variables  mentioned  above.  In  order  to 
develop  the  models,  other  variables  aside  from  the  driving  licence  directive’s  effect  on  road 
safety  were  also  selected  to  be  included.  When  selecting  the  variables  to  be  included  in  the 
statistical model, desk research was conducted to identify the most critical parameters relevant 
to  the  driving  licence  directive  and  road  safety.  The  modelling  methodology  is  presented  in 
detail in the support study. When developing the database it was decided that the key variables 
to be inserted in the model in order to quantify their impact on the target “fatalities per million 
population”  variable  were:  per  capita  GDP  (Gross  Domestic  Product);  vehicle  fleet  per 
population;  driving  licence  directives;  Directive  2003/59/EC  on  professional  driver  training; 
Directive 2008/96/EC on road infrastructure safety management. 

99 

 
 
 
Field research 

The  field  research  consisted  of  public  consultation  and  a  range  of  targeted  consultation 
activities detailed in Annex 2. Nine stakeholder groups299 were consulted in the context of the 
study by the following means:  

A targeted survey was launched on 31 August and was open until 11 December 2020. It was 
targeted  to  a  range  of  different  stakeholder  groups,  including  national  competent  authorities, 
but also all different industry sectors, and associative stakeholders representing road safety and 
road  users  associations,  drivers’  school  associations,  drivers’  associations,  automotive  and 
motorcycle  federations,  international  road  transport  associations,  and  vehicle  manufacturer 
associations.  This  online  survey  included  questions  on  the  effectiveness,  relevance,  and  EU 
added value of Directive 2006/126/EC. The questionnaire for national authorities was answered 
by national  authorities covering all  27 Member States. National authorities from  Iceland  and 
Norway also provided responses to the questionnaire. The questionnaire for non-governmental 
stakeholders was answered by 41 participants. 

Targeted  interviews  aimed  to  complement  the  questionnaires  by  collecting  more  details  on 
why stakeholders hold certain opinions, as well as to gather additional evidence in relation to 
evaluation questions for which qualitative data was judged to be an important source. A total of 
40 interviews were planned, out of which 29 were effectively carried out with a sample of key 
stakeholders  per main stakeholder type.  The interviews included 9 representatives of national 
authorities,  13  non-governmental  stakeholders  (associations  and  other  organisations)  and  2 
representatives from the European Commission. 

A  stakeholder  workshop  was  organised  with  competent  authorities  on  16  October  2020, 
aimed at the validation and discussion of preliminary findings with the stakeholder community. 
66  participants  attended,  including  representatives  from  driving  licence  authorities,  transport 
safety associations, road user associations, driving school associations, automotive associations 
and a motorcycle federation. 

An  open public  consultation300  was  held  from  28 October  2020  until  20 January  2021.  The 
consultation  specifically  related to the  relevance,  effectiveness,  coherence, efficiency  and  EU 
added value of the directive. A total of 546 responses were received.  

Three  case  studies  were  carried  out  the  methodology  for  establishing  a  link  between  the 
directive and its effects on road safety and free movement of citizens and quantifying them, on 
digital driving licences and on accompanied driving. 

The  data  collected  was  used  to  respond  to  the  evaluation  questions.  All  of  the  analytical 
findings  constitute  the  basis  for  the  assessment  on  how  the  directive  has  scored  on  the 

300   The  open  public  consultation  was  organised  by  the  European  Commission  and  consisted  of  an  online  questionnaire  published  on  a 
dedicated  Commission  webpage.  It  was  accessible  to  the  general  public  and  any  person  interested  in  the  topic  could  have  submitted  a 
contribution.  

100 

 
                                                           
 
evaluation  criteria.  Each  of  these  criteria  was  addressed  through  evaluation  questions,  as 
presented in the evaluation question matrix presented below.  

(2) 

Limitations and robustness of findings 

Even though the evaluation was designed to ensure the robustness of the evidence supporting 
its  findings,  limitations  to  the  robustness  of  certain  conclusions  were  identified  while 
conducting the analysis, and such limitations are inherent to this type of exercise.  

Limitations related to the COVID-19 crisis 

The  analysis  of  the  effect  on  road  safety  covers  the  period  2006  up  to  2018.  Thus,  the  study 
does not factor in recent socio-economic developments, specifically the COVID-19 crisis that 
had  an  unprecedented  impact  on  transport  and  mobility  of  European  citizens,  bringing  travel 
largely  to  a  standstill  for  several  months.  Unprecedented  reductions  in  traffic  volumes  have 
been  reported  across  Europe  since  confinement  measures  associated  with  the  COVID-19 
pandemic were introduced.301 Nevertheless this  reduction did  not  lead to  prolonged period of 
reductions  in  fatalities  and,  in  some  countries,  no  reductions  at  all  because  some  drivers 
increased speed.  

Limitations concerning the stakeholder consultation 

A key source of information were stakeholder consultation activities. Several challenges were 
encountered  in  the  collection  of  data  from  stakeholders,  but  mitigation  actions  were  taken. 
Some  key  limitations  related  to  the  stakeholder  activities  include  the  engagement  of 
stakeholders, particularly in light of the COVID-19 lockdown restrictions. 

For the survey with the non-governmental authorities, 41 responses were received and covered 
several stakeholder groups. Given the relatively limited number of responses, the findings from 
the survey of non-governmental authorities are not representative of the full population of non-
governmental stakeholders that are affected by the driving licence directive. 

For  the  open  public  consultation,  the  consultation  received  a  total  of  546  responses,  a  large 
proportion  of  them  from  the  Netherlands  (313).  This  is  interpreted  as  a  possible  result  of 
coordinated  action  of  certain  categories  of  stakeholders.  To  overcome  this  limitation,  the 
evaluation  presents  in  a  transparent  manner  the  data  sources  and  the  findings  and  highlights 
questions where there was a high proportion of stakeholders answering in the same or similar 
manners. Moreover, the total number of responses does not constitute a representative sample 
of  EU  citizens,  not  even  of  those  directly  affected  by  the  directive.  Thus,  the  results  of  the 
consultation cannot be interpreted to represent the views of all of the affected citizens. 

301   https://etsc.eu/pin-briefing-the-impact-of-covid-19-lockdowns-on-road-deaths-in-april-2020/  

101 

 
 
 
                                                           
Limitations concerning data availability  

The  evaluation  takes  place  40  years  after  the  implementation  of  the  first  driving  licence 
directive.  This  long  timespan  has  important  implications  in  terms  of  data  availability  for 
defining the baseline scenario, which gives rise to limitations in terms of the measurability of 
effects,  outcomes,  results,  costs,  and  benefits  arising  from  the  driving  licence  directive.  To 
overcome  this  lack  of  data,  some  assumptions  had  to  be  made,  relying  on  desk  research, 
consultation  of  stakeholders,  and  results  of  statistical  modelling  of  road  safety  trends  which 
ensures that the results are as robust and credible as possible. 

Concerning  the  analysis  of  the  effect  of  European  driving  licence  rules  on  road  safety 
(effectiveness),  statistics  on  road  accident  fatalities  are  available  from  1970  until  present  but 
only as total figures. Although providing robust evidence, the statistical modelling has several 
limitations,  since  road  safety  can  be  affected  by  many  factors  beyond  the  driving  licence 
directives (such as legislative, policy302, technological and demographic factors).  

However,  such  policies,  programmes  and  actions  cannot  be  included  in  statistical  models,  as 
they are not specific directives or guidelines that Member States would implement. In order to 
mitigate this limitation, the effects of such factors on road safety developments were taken into 
account and statistically estimated303 together with all other developments not included in the 
model  as  separate  variables  (e.g.  vehicle  technology,  road  infrastructure,  legislation  changes 
etc.).  

Concerning  the  contribution  of  the  driving  licence  directive  to  facilitating  free  movement 
across  EU  for  EU  citizens  (EQ  1),  literature  concerning  the  movement  of  persons  across  the 
borders and its relation to driving licence rules is very limited and mostly provides qualitative 
assessments of the extent to which the two are related. Similarly, statistical data on this is not 
available  to  monitor  and  assess  the  trends  over  time  and  the  effect  of  the  driving  licence 
directive on free movement. This constitutes a key limitation of the analysis. To mitigate this 
limitation, qualitative evidence was collected through stakeholder consultation to ascertain the 
perceived effect that the directive has had.  

Concerning the assessment of the impact of the directive on driving licence tourism and driving 
licence fraud (EQ 2.3), a key limitation constitutes the fact that there are no consistent statistics 
on driving licence fraud.  

Concerning  the  analysis  of  the  effect  of  the  absence  of  a  common  framework  on  driving’ 
disqualifications  on  road  safety  (EQ  6),  data  on  the  frameworks  in  place  in  countries  that 
mutually  recognise  disqualifications  was  not  made  available  in  the  data  collection  processes. 
Nevertheless, the analysis is still robust as it relies on evidence collected through desk research 
(e.g. analysis of Court of Justice rulings) as well as comprehensive consultation activities.  

302   For  instance,  the  Road  Safety  Action  Programme  (2003-2010),  the  Communication providing policy  orientations  on  road  safety  for  the 
period 2011-2020 and, most recently, the Valetta Declaration and the EU Road Safety Policy Framework 2021 -2030 – Next steps towards 
'Vision Zero' 

303   This was done through the random effects of the model. 

102 

 
                                                           
The analysis of efficiency (EQ 9 – 11) is relying on data collected via several data collection 
streams, including desk research and surveys of national authorities. Limitations concerning the 
analysis concern the availability of precise costs and administrative burden data associated with 
the  driving  licence  directive.  The  analysis  is  essentially  quantitative  with  diverging  views 
between  national  authorities  that  consider  that  administrative  burden  and  costs  have  been 
reduced, while citizens do not seem to have perceived that reduction.  

103 

 
(3) 

Evaluation questions matrix 

Effectiveness 

Sub-question 

Assessment / Judgement 
criteria 

Indicators  

Data sources  

Analytical approach 

EQ 1: At the level of its general objectives, to what extent (in quantitative and qualitative terms) has the directive contributed a) to enhance road safety b) to facilitate free movement for EU citizens? What have been the 
effects (positive or negative impacts) of the directive? 

EQ 1.1: To what extent has 
the directive contributed to 
enhanced road safety? 

EQ 1.1: The directive 
contributed to enhanced road 
safety.  

Trends in road traffic fatalities and/or 
serious injuries (compared to baseline) 

•  Reports and studies: e.g. European Commission (2017), 

Implementation study (e.g. Table 4.22 Overview of future measures 
for improvement in the area of road safety); Road Safety Atlas304 and 
Annual Accident Report305, based on Community database on 
Accidents on the Roads in Europe; European Commission (2019), 
Preliminary Road Safety Statistics306.  

•  Databases: Eurostat (Transport Accident Statistics307 and Transport 
Safety Statistics308); International Road Traffic Accident Database 
(IRTAD)309; ERF Statistics (2019)310;  

Comparison of road safety data 
trends (road fatalities and/or 
serious injuries) for different 
road user categories with the 
total road safety trends will 
allow us to assess how much 
provisions of the directive 
affecting different road user 
groups (such as motorcycle 
riders, novice and young riders, 
etc.) have contributed to 
improved road safety trends.  

•  TRID database311 

304   https://ec.europa.eu/transport/road_safety/specialist/statistics_en  

305   https://ec.europa.eu/transport/road_safety/statistics-and-analysis/data-and-analysis/annual-statistical-report_en  

306   https://ec.europa.eu/commission/news/road-safety-2019-apr-04_en 

307   https://ec.europa.eu/euros tat/statistics-explained/index.php?title=Archive:Transport_accident_statistics  

308   https://ec.europa.eu/eurostat/statistics-explained/index.php?title=Category:Transport_safety 

309   https://stats.oecd.org/Index.aspx?DataSetCode=IRTAD_CASUAL_BY_AGE  

310   https://erf.be/statistics/safety-2019/  

104 

 
                                                           
Sub-question 

Assessment / Judgement 
criteria 

Indicators  

Data sources  

Analytical approach 

•  Targeted survey with all stakeholder categories 

•  Targeted interviews with selected stakeholder groups 

•  Open Public Consultation 

EQ 1.2: To what extent has 
the directive contributed to 
facilitation of free 
movement for EU citizens? 

EQ 1.2: The directive 
contributed to facilitation of 
free movement for EU 
citizens. 

Contribution of provisions of the 
directive to free movement of citizens 

•  Reports and studies: e.g. European Commission (2017), 

Implementation study (e.g. Table 3.3. Overview of fees for driving 
licences before and after implementation of the third driving licence 
directive).  

•  Databases: Eurostat (e.g. EU citizens living in another Member State 
- statistical overview)312 for estimation of number of EU citizens 
moving from one country to another from) 

•  Targeted survey with national authorities and drivers' associations 
and drivers school associations and road users' associations / civil 
society and their members 

•  Targeted interviews with selected stakeholder groups 

Analysis of provisions of the 
directive or factors related to the 
directive that contributed to free 
movement (e.g. provisions on 
common licence, costs for 
driving licence renewal/ 
exchange/ replace).  

•  Measures (at Member State level) 
for mutual recognition of driving 

•  Reports and studies: e.g. European Commission (2017), 

Implementation study (e.g. Table 4.2 Overview of future measures 

Based on the desk and field 
research, the study team 
analysed which measures have 

311   Combines  the  records  from  TRB’s  Transportation Research  Information  Services  (TRIS)  Database  and the  OECD’s  Joint  Transport  Research Centre’s  International  Transport  Research Documentation  (ITRD) 

Database. 

312   https://ec.europa.eu/eurostat/statistics-explained/index.php/EU_citizens_living_in_another_Member_State_-_statistical_overview  

105 

 
 
 
 
                                                                                                                                                                                                                                                                                       
Sub-question 

Assessment / Judgement 
criteria 

Indicators  

Data sources  

Analytical approach 

licences in another Member State 

for improvement in the area of freedom of movement).  

•  Targeted survey to national authorities, drivers' associations and 
drivers school associations and Road safety and road users' 
associations / civil society and their members  

•  Targeted interviews with selected stakeholder groups 

been adopted by the Member 
States to implement the 
provision on mutual recognition 
of driving licences. Changes 
since the implementation of this 
provision would indicate 
positive developments regarding 
facilitation of free movement of 
the EU citizens. 

EQ 2. At the level of specific objectives: 

EQ 2.1: To what extent has the administrative burden for drivers and Member States been reduced, particularly when a driver changes his Member State of residence and subsequently the new Member State of 
residence exchanges his driving licence issued in another Member State? What are the remaining obstacles or difficulties in such a case? 

EQ 2.1: To what extent has 
the administrative burden 
been reduced for drivers 
and Member States? 

EQ 2.1: The administrative 
burden has been reduced for 
drivers and Member States, 
particularly in the case of 
change of residence. 

•  Administrative burden for first 
issuing, renewal, exchange, 
replacement of driving licences for 
citizens  

•  Reports and studies: e.g. European Commission (2017), 

Implementation study (e.g. Table 4.16 effects of administrative 
validity periods on costs for citizens).  

•  Targeted survey with national authorities and non-governmental 

stakeholders 

Analysis of provisions of the 
directive that have led to 
increased / decreased 
administrative burden for 
citizens and Member States 
national authorities.  

•  Processing time and required 
documentation for issuing, 
exchanging, replacing and 
renewing of driving licences for 
national authorities 

•  Reports and studies: e.g. European Commission (2017), 

Implementation study (e.g. Table 3.2 Overview of the duration of 
administrative processes for driving licences).  

•  Targeted survey with Member State authorities, drivers' associations 

and drivers school associations  

106 

 
 
 
Sub-question 

Assessment / Judgement 
criteria 

Indicators  

Data sources  

Analytical approach 

•  Targeted interviews with selected stakeholder groups 

•  Types of difficulties and obstacles 
for drivers wanting to change their 
driver licence in another Member 
State 

•  Reports and studies: e.g. European Commission (2017), 

Implementation study 

•  Targeted survey with national authorities and non-governmental 

stakeholders 

EQ 2.2: In which areas (e.g. validity periods, medical exams, training or testing) have uniform driving licence rules and requirements been established across Member States? In which areas are there still divergences? 

EQ 2.2: To what extent 
have uniform driving 
licence rules and 
requirements been 
established across the 
Member States concerning 
validity periods of driving 
licence, medical checks and 
trainings? 

EQ 2.2: Uniform driving 
licence rules and 
requirements have been 
established across the 
Member States concerning 
validity periods of driving 
licence, medical checks and 
trainings 

•  Instances of discrepancies in 

•  Reports and studies: e.g. European Commission (2017), 

administrative validity periods for 
driving licence categories 

•  Instances of discrepancies in 

administrative validity periods for 
replacing driving licences 

•  Instances of discrepancies in 
limited administrative validity 
periods for first licence issued to 
novice drivers 

Implementation study (e.g. Table 4.2 Overview of administrative 
validity periods for driving licence category A-B, Table 4.3 
Motivation for chosen administrative validity period for driving 
licences of categories A-B, Table 4.4 administrative validity period 
of replacement driving licence., Table 4.5 administrative validity 
periods for driving licence category B and C, Table 4.6 for first 
licence issues to novice drivers (categories A-B and C-D), Table 4.7 
limited administrative validity periods, Table 4.17 medical 
examination for categories AM/A1/A2/A/B1/B upon renewal, Table 
4.18 medical examination for categories C, CE, C1, C1E, D, DE, D1, 
D1E upon renewal, Table 4.23 future measures for improvement in 
the area of medical checks); European Commission (2017), Study on 
driver training, testing and medical fitness (2017); CIECA (2017), 
Guide on Driver Licencing: The driving licence encyclopaedia of the 

The study team will update the 
existing information regarding 
discrepancies in specific driving 
licence rules and requirements 
by consulting Member States 
and asking them to validate/ 
update existing mappings on 
variations in terms of 
implementation of different 
provisions in the Member 
States.  

107 

 
 
Sub-question 

Assessment / Judgement 
criteria 

Indicators  

Data sources  

Analytical approach 

International Commission for Driver Testing313.  

•  Targeted survey with Member State authorities and other 

stakeholders  

•  Targeted interviews with selected stakeholder groups 

•  Instances of discrepancies in 

medical checks upon renewal for 
driving licence categories A-B 

•  Instances of discrepancies in 

mandatory medical examinations 
for categories C-D upon renewal 

•  Instances of discrepancies in 

minimum standards for driving 
examiners including quality 
assurance and regular periodic 
training 

EQ 2.3: To what extent have the possibilities of driving licence fraud and “driving licence tourism” been reduced? 

EQ 2.3: To what extent 
have driving licence fraud 
and driving licence tourism 
been reduced due to the 
directive? 

EQ 2.3: Fraud and driving 
licence tourism have been 
reduced due to the directive.  

•  Instances of driving licence fraud/ 
forgery and driving licence 
tourism  

•  Reports and studies: e.g. European Commission (2017), 

Implementation study (e.g. Table 4.21 Overview of future measures 
for improvement in the area of anti-fraud protection, Table 8.4 
overview of the effects of RESPER on driving licence fraud); EReg 
Topic Group X (2011), Report on Driving Licence Tourism.  

Analytical approach as 
described under EQ 1.1 on 
trends in instances of driving 
licence fraud/forgery and 
driving licence tourism 

•  Infringement proceedings 

•  Data from RESPER network (to be determined based on input from 

313   The information is available to CIECA members. See: https://www.cieca.eu/  

108 

 
                                                           
Sub-question 

Assessment / Judgement 
criteria 

Indicators  

Data sources  

Analytical approach 

DG MOVE on the contents of RESPER) 

•  Targeted survey with national authorities, drivers' associations and 

drivers school associations  

•  Targeted interviews with selected stakeholder groups 

•  Open Public Consultation 

Based on the information 
provided by EC expert on 
RESPER and information 
provided by Member States in 
interviews and survey, the study 
team will analyse the frequency 
and situations in which 
information accessed via 
RESPER has been used by 
competent authorities. The 
analysis will look also into other 
possible procedures to verify 
normal residence in order to 
assess, whether driving licence 
fraud and driving licence 
tourism can be successfully 
detected by the Member States. 

•  Level of use and exchange of 
information via RESPER by 
authorities when issuing, 
exchanging, replacing, renewing, 
revoking driving licences 

•  Reports and studies: e.g. European Commission (2017), 

Implementation study (e.g. Table 7.3 overview of the system being 
used to connect to RESPER, Table 7.4 and 7.5 on the interface of 
RESPER system, Table 7.6 average number of monthly sent and 
received requests through RESPER).  

•  Data from RESPER network (to be determined based on input from 

DG MOVE on the contents of RESPER) 

•  Targeted survey with Member State authorities, RESPER 

representatives 

•  Targeted interviews with selected stakeholder groups 

•  Procedures to verify normal 

•  Reports and studies: e.g. European Commission (2017), 

residence in different Member 
States 

Implementation study (e.g. Table 4.12: Overview of procedure to 
check normal residence); EReg Topic Group X (2012), Report on 
Normal Residence.  

•  Targeted survey with Member State national authorities, road safety 
and road users' associations / civil society and their members, 

109 

 
Sub-question 

Assessment / Judgement 
criteria 

Indicators  

Data sources  

Analytical approach 

transport associations 

•  Targeted interviews with selected stakeholder groups 

•  Open public consultation  

EQ 2.4: To what extent have the driving skills of non-professional and professional drivers been raised? 

EQ 2.4: To what extent 
have the driving skills of 
non-professional and 
professional drivers 
increased as a result of the 
provisions of the directive? 

EQ 2.4: The driving skills of 
non-professional and 
professional drivers have 
increased as a result of the 
provisions of the directive.  

•  Change in the level of skills of 
professional drivers (e.g. 
knowledge and understanding of 
driving and assessment 
competences, personal driving 
skills and quality of service, 
vehicle technique and physics 
requirements) 

•  Reports and studies: e.g. European Commission (2017), Study on 

driver training, testing and medical fitness.  

•  Targeted survey with national authorities, drivers' associations and 
drivers school associations and road transport associations  

Based on the results from desk 
review and additional field 
research, the team will explore 
whether targeted stakeholders 
perceive improvements in 
driving skills for professional 
and non-professional drivers.  

•  Targeted interviews with selected stakeholder groups 

•  Open public consultation  

•  Change in the level of skills of 
non-professional drivers 

•  Reports and studies: e.g. European Commission (2017), Study on 

driver training, testing and medical fitness.  

•  Targeted survey with national authorities, drivers' associations and 
drivers school associations and road transport associations  

•  Targeted interviews with selected stakeholder groups 

•  Open public consultation  

110 

 
Sub-question 

Assessment / Judgement 
criteria 

Indicators  

Data sources  

Analytical approach 

EQ 2.5: To what extent have the provisions on the qualification of driving examiners contributed to safe driving? Is the relevant monitoring framework fit for that purpose? 

EQ 2.5: To what extent 
have the provisions on the 
qualification of driving 
examiners contributed to 
safe driving? 

EQ 2.5: The provisions on the 
qualification of driving 
examiners contributed to safe 
driving (with less road 
fatalities and/or serious 
injuries). 

•  Requirements for qualifications for 
driving examiners at the level of 
Member States  

•  Reports and studies: e.g. European Commission (2017), Study on 
driver training, testing and medical fitness, European Commission 
(2014), Novice driver preparation - an international comparison.  

•  Targeted survey with national authorities, drivers' associations and 
drivers school associations and road transport associations  

•  Targeted interviews with selected stakeholder groups 

•  Extent to which the requirements 
of qualifications for driving 
examiners led to safe driving 

•  Targeted survey with national authorities, drivers' associations and 
drivers school associations and road transport associations  

•  Targeted interviews with selected stakeholder groups 

•  Novice drivers involved in road 
fatalities and/or serious injuries 

•  Reports and studies: e.g. European Commission (2017), 

Implementation study (e.g. Table 4.22 Overview of future measures 
for improvement in the area of road safety); Road Safety Atlas314 and 
Annual Accident Report315, based on Community database on 
Accidents on the Roads in Europe; European Commission (2019), 
Preliminary Road Safety Statistics316.  

The study team analysed 
Member States' national 
requirements for qualifications 
for driving examiners at the 
level of Member States and how 
important these provisions are 
for road safety as perceived by 
various stakeholders. 

The conclusion will be made on 
the assumption that a better 
qualified examiner means lower 
probability of novice drivers 
involved in road fatalities and/or 
serious injuries.  

314   https://ec.europa.eu/transport/road_safety/specialist/statistics_en  

315   https://ec.europa.eu/transport/road_safety/sites/roadsafety/files/pdf/statistics/dacota/asr2018.pdf  

316   https://ec.europa.eu/commission/news/road-safety-2019-apr-04_en 

111 

 
 
                                                           
Sub-question 

Assessment / Judgement 
criteria 

Indicators  

Data sources  

Analytical approach 

•  Databases: Eurostat (Transport Accident Statistics317 and Transport 
Safety Statistics318); International Road Traffic Accident Database 
(IRTAD)319; ERF Statistics (2019)320;  

•  TRID database321 

•  Targeted survey with all stakeholder categories 

EQ 2.6: To what extent have novice and/or young motorcycle drivers been protected in terms of road safety? 

EQ 2.6: To what extent are 
the provisions for novice 
and young motorcycle 
drivers sufficient to ensure 
road safety? 

EQ 2.6: The provisions for 
novice and young motorcycle 
drivers are sufficient to ensure 
road safety.  

•  Number of young and novice 
motorcycle drivers involved in 
traffic fatalities and/or serious 
injuries 

•  Reports and studies: e.g. Road Safety Atlas322 and Annual Accident 
Report (2018); Study on driver training, testing and medical fitness 
(2017); SafetyNet (2009); Novice Drivers, DaCoTA (2012); Novice 
Drivers ERSO (2015); European Commission (2018); Novice Drivers 

Based on statistical analysis, 
field research and desk research 
an assessment of the impact of 
the provisions of the directive 
on novice and motorcycle divers 
was made. 

EQ 2.7: To what extent has the application and the enforcement of driving licence rules by Member States been facilitated? 

317   https://ec.europa.eu/euros tat/statistics-explained/index.php?title=Archive:Transport_accident_statistics  

318   https://ec.europa.eu/eurostat/statistics-explained/index.php?title=Category:Transport_safety 

319   https://stats.oecd.org/Index.aspx?DataSetCode=IRTAD_CASUAL_BY_AGE  

320   https://erf.be/statistics/safety-2019/  

321   Combines  the  records  from  TRB’s  Transportation Research  Information  Services  (TRIS)  Database  and the  OECD’s  Joint  Transport  Research Centre’s  International  Transport  Research Documentation  (ITRD) 

Database. 

322    

https://ec.europa.eu/transport/road_safety/specialist/statistics_en  

112 

 
                                                           
Sub-question 

Assessment / Judgement 
criteria 

Indicators  

Data sources  

Analytical approach 

EQ 2.7: To what extent has 
the application and 
enforcement of driving 
licence rules has been 
facilitated? 

EQ 2.7: The application and 
enforcement of driving 
licence rules has been 
facilitated by RESPER. 

•  Number of Member States 

connected to RESPER through 
national database directly and 
through EUCARIS 

•  Reports and studies: European Commission (2017), Implementation 
study (e.g. Table 8.2: Overview of RESPER characteristics).  

•  Data from RESPER network (to be determined based on input from 

DG MOVE on the contents of RESPER) 

•  Level of use and exchange of 
information via RESPER by 
Member States in terms of 
information on the licences they 
have issued, exchanged, replaced, 
renewed or revoked 

•  Reports and studies: e.g. Grimaldi (2012), Assistance with the 
verification of compliance of national legislative measures 
implementing Directive 2006/126/EC, as amended by directive 
2009/113/EC (Horizontal assessment report); European Commission 
(2017), Implementation study (e.g. Table 8.2: Overview of RESPER 
characteristics).  

•  Data from RESPER network (to be determined based on input from 

DG MOVE on the contents of RESPER) 

•  Targeted survey and interviews with national driving licence 

authorities 

•  Open public consultation 

The study team will assess 
usefulness and reliability of 
information accessed through 
RESPER as perceived by 
national competent authorities. 
This analysis will lead to a 
conclusion, whether RESPER is 
a successful tool for application 
and the enforcement of driving 
licence rules. 

•  Instances of driving licence fraud 
and driving licence tourism 

EQ 2.7: The application and 
enforcement of driving 
licence rules has led to 
reduced number of instances 
of driving licence fraud and 
driving licence tourism. 

•  Reports and studies: e.g. European Commission (2017), 

Implementation study (e.g. Table 4.21 Overview of future measures 
for improvement in the area of anti-fraud protection, Table 8.4 
overview of the effects of RESPER on driving licence fraud); EReg 
Topic Group X (2011), Report on Driving Licence Tourism.  

•  Infringement proceedings, Rulings of the Court of Justice 

•  Data from RESPER network (to be determined based on input from 

See analytical approach under 
EQ 1.1 on instances of driving 
licence fraud and driving 
licence tourism. 

Reduced number of instances of 
driving licence fraud and 
driving licence tourism would 
support the assumption that 
application and enforcement of 
driving licence rules has been 

113 

 
 
Sub-question 

Assessment / Judgement 
criteria 

Indicators  

Data sources  

Analytical approach 

DG MOVE on the contents of RESPER) 

facilitated. 

•  Targeted survey with national authorities, drivers' associations and 

drivers school associations  

•  Targeted interviews with selected stakeholder groups 

•  Open Public Consultation 

EQ 3: To what extent has RESPER facilitated the objectives of the directive and what are its shortcomings, if any? 

EQ 3.1: To what extent has 
RESPER facilitated the 
achievement of the general 
objectives of the directive? 

EQ 3.1: RESPER facilitated 
the achievement of objectives 
of the directive (i.e. free 
movement of people and road 
safety). 

•  Level of simplification of 

•  Reports and studies: e.g. European Commission (2017), 

administrative processes for 
checking driving licence validity 

Implementation study (Annex 8: Table 8.6: Overview of the effects 
of RESPER on the update and verification of driving licence 
information, Table 8.16: Overview of future measures for 
improvement in the area of enforcement, Table 8.7: Overview of the 
procedure to check the validity of an applicants’ request in different 
situations (Before RESPER), Table 8.8: Overview of the procedure to 
check the validity of an applicants’ request in different situations 
(After RESPER).  

•  Targeted survey with different stakeholders, Member State 

authorities, national driving licence authorities and road safety, road 
users' associations / civil society and their members 

•  Targeted interviews with selected stakeholder groups 

•  Open public consultation 

114 

Based on the existing research 
and additional field research 
(survey and interviews), the 
study team will assess, whether 
the introduction of RESPER has 
led to simplified procedures for 
checking driving licence 
validity.  

Simplification will be measured 
in terms of availability of 
information and verification 
tools, as well as Member States' 
general perceptions. 

 
 
Sub-question 

Assessment / Judgement 
criteria 

Indicators  

Data sources  

Analytical approach 

•  Level of use and exchange of 
information via RESPER by 
Member States in terms of 
information on the licences they 
have issued, exchanged, replaced, 
renewed or revoked 

•  Reports and studies: e.g. European Commission (2017), 

Implementation study (e.g. Table 8.2: Overview of RESPER 
characteristics).  

•  Data from RESPER network (to be determined based on input from 

DG MOVE on the contents of RESPER) 

See analytical approach under 
EQ 2.7 level on use and 
exchange of information via 
RESPER by Member States in 
terms of information on the 
licences they have issued, 
exchanged, replaced, renewed 
or revoked 

•  Targeted survey with national driving licence authorities 

•  Targeted interviews with selected stakeholder groups 

•  Open public consultation 

•  Instances of document fraud 

•  Data from RESPER network (to be determined based on input from 

identified with the aid of RESPER 

DG MOVE on the contents of RESPER) 

•  Targeted survey with national authorities, drivers' associations and 

drivers school associations  

•  Targeted interviews with selected stakeholder groups 

•  Open Public Consultation 

The aim of this indicator is to 
identify a proportion of 
document fraud instances 
identified with the aid of 
RESPER as compared to other 
possible sources. 

EQ 3.2: Do RESPER 
facilities have any 
shortcomings that need to 
be overcome to further 
facilitate the achievement 

EQ 3.2: RESPER has/does 
not have shortcomings that 
need to be overcome to 
further facilitate the 

•  Shortcomings/ areas for 
improvement of RESPER 

•  Reports and studies: e.g. European Commission (2017), 

Implementation study (e.g. Table 8.2: Overview of RESPER 
characteristics).  

•  Data from RESPER network (to be determined based on input from 

Based on the existing research 
and additional field research 
(survey and interviews), the 
study team will assess, whether 
stakeholders identify any 
shortcomings and areas for 

115 

 
Sub-question 

Assessment / Judgement 
criteria 

Indicators  

Data sources  

Analytical approach 

of the objectives? 

achievement of the objectives. 

DG MOVE on the contents of RESPER) 

improvements. 

•  Level of usefulness of RESPER 
services (e.g. Search Driving 
Licence by Name, Get Driving 
Licence Details, Notify Driving 
Licence Status, Secure Message) 

Based on the existing research 
and additional field research 
(survey and interviews) to 
update the existing knowledge, 
the study team will assess 
usefulness of RESPER services 
as perceived by relevant 
stakeholders. 

•  Targeted survey with different stakeholders, Member State 

authorities and national driving licence authorities 

•  Targeted interviews with selected stakeholder groups 

•  Reports and studies: e.g. European Commission (2017), 

Implementation study (Table 7.7: Overview of how satisfied the 
Member States are with the SDLN service in RESPER, Table 7.8: 
Overview of the way in which Member States send SDLN requests 
and Table 7.9: Overview of issues with Member States not 
responding to SDLN requests, Table 7.10: Overview of how satisfied 
the Member States are with the GDLD service in RESPER, Table 
7.11: Overview of how the GDLD services is applied by each 
Member State and Table 7.12: Overview of issues with Member 
States not responding to GDLD requests, Table 7.13: Overview of 
how satisfied the Member States are with the NDLS service in 
RESPER and Table 7.14: Overview of issues with Member States not 
responding to NDLS requests, Table 7.15: Overview of the 
implementation and use of secure messages, Table 7.16: Overview of 
how satisfied the Member States are with the secure messages service 
in RESPER and Table 7.17: Overview of issues with Member States 
not responding to secure messages).  

•  Data from RESPER network (to be determined based on input from 

DG MOVE on the contents of RESPER.) 

•  Targeted survey with national driving licence authorities, RESPER 

•  Targeted interviews with selected stakeholder groups 

116 

 
Sub-question 

Assessment / Judgement 
criteria 

Indicators  

Data sources  

Analytical approach 

EQ 4: To what extent the possible differences between Member States resulting from the lack of minimum and/or harmonised training obligations for learner drivers have had an impact on road safety? 

EQ 4.1: To what extent 
have differences between 
Member States in terms of 
training requirements an 
impact on road safety? 

EQ 4.1: Differences between 
Member States in terms of 
training requirements have an 
impact on road safety.  

The study team will update the 
existing mapping on training 
requirements with further field 
research.  

•  Training obligations and 

•  Reports and studies: European Commission (2017),  

requirements in the Member States 
for novice drivers  

•  Study on driver training, testing and medical fitness; Mapping by the 
European Driving School Association on requirements for novice 
drivers; ETSC (2018), Briefing: 5th EU Road Safety Action 
Programme 2020-2030; Study on driver training, testing and medical 
fitness (2017).  

•  Targeted survey to national driving licence authorities, drivers' 

associations and drivers school associations, road safety and road 
users' associations / civil society and their members, insurance 
companies, road transport associations, insurance companies  

•  Targeted interviews with selected stakeholder groups 

•  Case study 3 – Accompanied driving for category B driving licences 

•  Open public consultation 

•  Level of impact of varying 

requirements and obligations for 
training in the Member States on 
road safety 

•  Targeted survey with national driving licence authorities, drivers' 
associations and drivers school associations, road safety and road 
users' associations / civil society and their members, insurance 
companies, road transport associations, insurance companies  

•  Targeted interviews with selected stakeholder groups 

•  Open public consultation 

117 

Impact of varying training 
requirements and obligations on 
road safety will be analysed 
through stakeholder 
consultations, including targeted 
survey, interviews and Open 
Public Consultation. 

 
Sub-question 

Assessment / Judgement 
criteria 

Indicators  

Data sources  

Analytical approach 

•  Number of novice drivers involved 
in traffic fatalities and/or serious 
injuries 

•  Reports and studies: e.g. Study on driver training, testing and medical 

fitness (2017).  

•  Targeted survey with driver's associations and drivers school 

associations, road safety and road users' associations / civil society 
and their members, road transport associations  

•  Targeted interviews with selected stakeholder groups 

•  Open public consultation 

The assumption made here is 
that harmonised training 
obligations for learner drivers 
leads to lower probability of 
novice drivers involved in road 
fatalities and/or serious injuries. 

The analytical approach is 
aligned with the baseline 
approach. 

EQ 5: What has been the impact, if any, of differences across Member States regarding the recognition of driving licences issued by third countries, for example in relation to driver shortage for EU hauliers? 

EQ 5.1: To what extent 
have differences across 
Member States on 
recognition of driving 
licences issued by third 
country an impact on driver 
shortage and other issues? 

EQ 5.1: Differences across 
Member States on recognition 
of driving licences issued by 
third country had an impact 
on driver shortage and other 
issues. 

•  Differences between Member 
States in recognition of driving 
licence issued by third countries 
(e.g. processing, validating, 
renewing driving licence) 

•  Targeted survey with interviews with different stakeholders, Member 

State authorities 

•  Targeted interviews with selected stakeholder groups 

•  Open public consultation 

Based on the results from field 
research, the team will identify 
any issues that the Member 
States might encounter due to 
the differences across Member 
States regarding the recognition 
of driving licences issued by 
third countries. 

•  Types and scale of impact of the 
different procedures for handling 
driving licence from third country 
on driver shortage (e.g. for EU 
hauliers) 

•  Targeted survey with interviews with different stakeholders, Member 

State authorities 

•  Targeted interviews with selected stakeholder groups 

•  Open public consultation 

118 

 
Sub-question 

Assessment / Judgement 
criteria 

Indicators  

Data sources  

Analytical approach 

EQ 6: What has been the impact, if any, of the absence of an EU framework for the mutual recognition of driving disqualifications on road safety in general and on driving licence tourism in particular? 

EQ 6.1: To what extent has 
the absence of an EU 
framework for the mutual 
recognition of driving 
disqualifications an impact 
on road safety, particularly 
concerning driving licence 
tourism? 

EQ 6.1: The absence of an 
EU framework for the mutual 
recognition of driving 
disqualifications had an 
impact on road safety, 
particularly concerning 
driving licence tourism. 

•  Current practices in terms of 
mutual recognition of driving 
disqualifications in the Member 
States 

•  Reports and studies: e.g. Evaluation Study on the Application of 
directive 2011/82/EU Facilitating the Cross-Border Exchange of 
Information on Road Safety Related Traffic Offences.  

•  Targeted survey of national authorities 

•  Targeted interviews with selected stakeholder groups 

Based on the results from the 
existing research and additional 
field research, the team will 
identify any issues that the 
Member States might encounter 
due to the absence of an EU 
framework for the mutual 
recognition of driving 
disqualifications, especially in 
terms of driving licence tourism.  

•  Type and scale of impact of 
absence of EU framework for 
mutual recognition of driving 
disqualifications on road safety 
and driving licence tourism 

•  Targeted survey with national driving licence authorities, drivers' 
associations and drivers school associations, road safety and road 
users' associations / civil society and their members, insurance 
companies, road transport associations, insurance companies  

•  Targeted interviews with selected stakeholder groups 

•  Open public consultation 

EQ 7: Which factors have contributed to/hindered the achievement of objectives? 

EQ 7.1: Which types of 
factors have hindered or 
contributed to achieving 
road safety? 

EQ 7.1: Types of factors that 
have hindered or contributed 
to achieving road safety  

•  Typology of factors that have 
contributed or hindered the 
achievement of road safety  

•  Reports and studies: e.g. WHO Global Status Report on Road Safety 

(2018).  

•  Targeted survey of national driving licence authorities, drivers' 

associations and drivers school associations, road safety and road 
users' associations / civil society and their members, insurance 

Based on the results from the 
existing research and additional 
field research, the team will 
identify any types of factors that 
have hindered or contributed to 
achieving road safety and free 
movement of EU citizens. 

119 

 
 
Sub-question 

Assessment / Judgement 
criteria 

Indicators  

Data sources  

Analytical approach 

companies, road transport associations, insurance companies  

•  Targeted interviews with selected stakeholder groups 

•  Open public consultation  

EQ 8: Has the directive led to any positive or negative unexpected effects? 

EQ 8.1: Has the directive 
led to any unexpected 
effects? 

EQ 8.1: The directive has led 
to unexpected effects. 

•  Unintended positive effects of the 
directive (e.g. citizens benefiting 
from improved transport security)  

•  Unintended negative effects of the 
directive (e.g. novice drivers 
facing increased costs for 
obtaining driving licence, more 
unlicenced novice drivers)  

•  Evidence collected under the previous questions on effectiveness  

•  Targeted survey of national driving licence authorities, drivers' 

associations and drivers school associations, road safety and road 
users' associations / civil society and their members, insurance 
companies, road transport associations, insurance companies  

Based on the results from the 
field research, the team will 
identify any positive or negative 
unexpected effects as perceived 
by various stakeholders. 

•  Targeted interviews with selected stakeholder groups 

•  Open public consultation  

120 

 
 
 
Efficiency 

Sub-question 

Assessment / Judgement 
criteria 

Indicators  

Data sources  

Analytical approach 

EQ 9: Has the directive resulted in any excessive costs/negative impacts as regards 

EQ 9.1. Introducing a national driving licence based on a new single Community Model? 

EQ 9.1.1: What have been 
the costs and burden for 
introducing a national 
driving licence based on a 
new single Community 
Model? 

EQ 9.1.1: Costs and burden 
for introducing a national 
driving licence based on a 
new single Community 
Model.  

•  Costs associated with the new EU 
driving licence model for EU 
citizens (e.g. processing fees 

•  Reports and studies: e.g. European Commission (2017), 

Implementation study: Chapter 3.1 Union Model Licence, Table 3.3 
Overview of fees for driving licences before and after 
implementation of the third driving licence directive).   

•  EC webpage: Europa.eu323 (information by national authorities of all 
Members States except HR, LT and SK on the process of driving 
licence renewal in another EU country; on driving licence 
recognition, exchange). 

•  Targeted survey with Member State authority's driver's associations 

and driver's school associations, road safety and road users' 
associations / civil society and their members, road transport 
associations and industry associations 

The study team will assess based on the 
existing research and additional field 
research, whether the introduction of the new 
driving single Community Model has led to 
additional costs and administrative burden 
for the EU citizens. 

323   https://europa.eu/youreurope/citizens/vehicles/driving-licence/driving-licence-renewal/index_en.htm 

121 

 
 
 
 
 
                                                           
Sub-question 

Assessment / Judgement 
criteria 

Indicators  

Data sources  

Analytical approach 

•  Level of administrative burden 
associated with the new EU 
driving licence model for EU 
citizens (processing time, 
requirements for application) 

•  Targeted interviews with selected stakeholders 

•  Reports and studies: e.g. European Commission (2017), 

Implementation study: Chapter 3.1 Union Model Licence (in 
particular information on costs for citizens.  

•  Targeted survey and interviews with Member State authority's 

driver's associations and driver's school associations, road safety and 
road users' associations / civil society and their members, road 
transport associations and industry associations 

•  Targeted interviews with selected stakeholders 

•  Level of administrative burden 
associated with the new EU 
driving licence model of for 
national authorities (e.g. changes 
in staffing costs related to 
processing the single Community 
Model driving licence) 

•  Reports and studies: e.g. European Commission (2017), 

Implementation study: Chapter 3.1 Union Model Licence (in 
particular information on data storage, duration of administrative 
processes, and administrative burden for public administration before 
and after the introduction of the Union Model Licence, e.g. Table 
3.2: Overview of the duration of administrative processes.  

•  Targeted survey and interviews with Member State authorities 

•  Targeted interviews with selected stakeholders 

EQ 9.1.2: What have been 
the benefits and other types 
of impacts of the 
introduction of the national 

EQ 9.1.2: Benefits and other 
types of impacts of the 
introduction of the national 
driving licence based on a 

•  Change in number of fraud cases 
and level of security since the 
introduction of the new single 

•  Findings and data sources under EQ 1.1 on trends in instances of 

driving licence fraud and driving licence tourism 

Based on the existing research and additional 
field research, the study team will assess 
trends of driving licence fraud since the 
introduction of the new single Community 

122 

 
Sub-question 

Assessment / Judgement 
criteria 

driving licence based on a 
new single Community 
Model? 

new single Community 
Model 

Indicators  

Data sources  

Analytical approach 

Community Model  

•  Reports and studies: e.g. European Commission (2017), 

Implementation study: Chapter 3.1.3 Overview and assessment of 
advanced and future functionalities and reliability (in particular the 
information on advanced anti-fraud measures, status of 
implementation of the microchip, potential of non-physical driving 
licence, digital features for physical driving licence, etc.).  

•  Targeted survey and interviews with national driving licence 

authorities, drivers' associations and drivers school associations, road 
safety and road users' associations / civil society and their members 
as well as road transport associations  

•  Targeted interviews with selected stakeholders 

•  Open Public Consultation 

•  Change in number of different 
licence models in circulation 
across the EU 

•  Studies and reports: e.g. European Commission (2015), Driving 

Licence Handbook. 

•  EC webpage: Driving licence models - Europa website324 

Model (to the extent that such data is 
available).  

Reduced number of driving licence fraud and 
driving licence tourism means reduced 
number of unlicenced drivers, who have not 
been properly trained. Such unlicenced 
drivers pose danger for themselves and other 
road users and therefore less fraud translates 
into a positive benefit for all road users. 

Based on the existing research and additional 
field research, the study team will assess 
whether the introduction of the national 
driving licence based on a new single 
Community Model has led to a reduced 
number of different licence models across 
the EU. Reduced number will showcase 
simplification of validity checks across the 
EU as a benefit for the competent national 
authorities. 

324   See: https://ec.europa.eu/transport/road_safety/topics/driving-licence/models_en 

123 

 
 
                                                           
Sub-question 

Assessment / Judgement 
criteria 

Indicators  

Data sources  

Analytical approach 

EQ 9.2. Establishing uniform driving licence rules and requirements? And in particular as regards age limits, driving licence validity periods and exceptions? 

EQ 10.2.1: What have been 
the costs and burden for 
harmonisation of age limits, 
driving licence validity 
periods and the exceptions? 

EQ 10.2.1: Costs and burden 
for harmonisation of age 
limits, driving licence 
validity periods and the 
exceptions 

•  Compliance costs in relation to 
driving licence renewal 
requirements (e.g. validity period, 
physical and mental fitness 
examination, age limits) 

•  Targeted survey with national driving licence authorities, drivers' 

associations and drivers school associations 

•  Targeted interviews with selected stakeholders 

Based on the existing research and additional 
field research, the study team will assess the 
costs and administrative burden related to 
harmonisation of driving licence rules, in 
particular as regards age limits, driving 
licence validity periods and exceptions, as 
perceived by national authorities and other 
stakeholders. 

•  Costs and administrative burden 
for authorities in relation to 
requirements related to renewal of 
driving licences (e.g. validity 
periods and exemptions, age 
limits) 

•  Reports and studies: e.g. European Commission (2017), 

Implementation study: Chapter 4.1.2 Harmonised administrative 
validity periods and medical checks, Chapter 3.3 Modification of 
driving licence categories, Chapter 3.1.2.6 Administrative burden for 
public administration: storage and delivery. 

•  Targeted survey and interviews with national driving licence 

authorities 

•  Targeted interviews with selected stakeholders 

EQ 9.2.2: What have been 
the benefits and other types 
of impacts of the uniform 
driving licence rules and 

EQ 9.2.2: Benefits and other 
types of impacts of the 
uniform driving licence rules 
and requirements (e.g. 

•  Road safety trends that can be 

•  Reports and studies: e.g. European Commission (2017), 

correlated to the requirements of 

Implementation study (e.g. Table 4.22 Overview of future measures 
for improvement in the area of road safety); Road Safety Atlas325 and 
Annual Accident Report326, based on Community database on 

Based on the results from the desk and field 
research, the team will identify any benefits 
and other types of impacts of the uniform 
driving licence rules and requirements as 

325   https://ec.europa.eu/transport/road_safety/specialist/statistics_en  

326   https://ec.europa.eu/transport/road_safety/sites/roadsafety/files/pdf/statistics/dacota/asr2018.pdf  

124 

 
 
 
 
 
                                                           
Sub-question 

Assessment / Judgement 
criteria 

requirements (e.g. 
introduction of rules on age 
limits, driving licence 
validity periods and the 
exceptions)? 

introduction of rules on age 
limits, driving licence 
validity periods and the 
exceptions) 

Indicators  

Data sources  

Analytical approach 

the directive 

Accidents on the Roads in Europe; European Commission (2019), 
Preliminary Road Safety Statistics327.  

perceived by various stakeholders. 

•  Databases: Eurostat (Transport Accident Statistics328 and Transport 
Safety Statistics329); International Road Traffic Accident Database 
(IRTAD)330; ERF Statistics (2019)331;  

•  TRID database332 

•  Targeted survey with all stakeholder categories 

•  Targeted interviews with selected stakeholder groups 

•  Open Public Consultation 

•  Benefits of harmonising rules on 
age limits, validity periods and the 
related exceptions 

•  Reports and studies: e.g. European Commission (2017), 

Implementation study: in particular Table 4.15: Overview of the 
effects of administrative validity periods on administrative burden for 

327   https://ec.europa.eu/commission/news/road-safety-2019-apr-04_en 

328   https://ec.europa.eu/euros tat/statistics-explained/index.php?title=Archive:Transport_accident_statistics  

329   https://ec.europa.eu/eurostat/statistics-explained/index.php?title=Category:Transport_safety 

330   https://stats.oecd.org/Index.aspx?DataSetCode=IRTAD_CASUAL_BY_AGE  

331   https://erf.be/statistics/safety-2019/  

332   Combines the records from TRB’s Transportation Research Information Services (TRIS) Database and the OECD’s Joint Transport Research Centre’s International Transport Research Documentation (ITRD) Database. 

125 

 
 
                                                           
Sub-question 

Assessment / Judgement 
criteria 

Indicators  

Data sources  

Analytical approach 

EQ 9.3: Strengthening the principle of progressive access to category A driving licences? 

EQ 9.3.1: What have been 
the costs and burden for 
progressive access to 
category A driving licences? 

EQ 9.3.1: Costs and burden 
for progressive access to 
category A driving licences 

•  Costs for citizens for first issuing, 
exchanging, replacing the 
category A driving licence via 
progressive access as compared to 
direct access 

citizens.  

•  Targeted survey and interviews national driving licence authorities, 
driver's associations and drivers school associations, road safety and 
road users' associations / civil society and their members and road 
transport associations 

•  Targeted interviews with selected stakeholders 

•  Open Public Consultation 

•  Report and studies: e.g. European Commission (2017), 

Implementation study: Chapter 3.3 Modification of driving licence 
categories; Delhaye, A., Marot, L. (2015), A European Scanning 
Tour for Motorcycling Safety, Final Report of the EC/MOVE/C4 
project RIDERSCAN: Chapter 2.2. Improving access to PTWs; 
Annex 2: User Survey – Feedback from European riders on the 
3DLD implementation (Chapter 3.4. Opinion about the new licence 
scheme), Annex 4: Member States Amplifying Questions – EU Road 
Safety Authorities’ views and recommendations, Annex 5: 
Motorcycling Community Amplifying Questions - Riders and 
Industry Safety Experts’ views and recommendations, etc.  

•  Targeted survey with national driving licence authorities and driver's 

associations and drivers school associations 

•  Targeted interviews with selected stakeholders 

The aim of this assessment is to conclude 
whether the introduction of progressive 
access to category A driving licences has 
incurred much higher costs as compared to 
costs for obtaining category A driving 
licences through direct access.  

Through additional indicators, the study 
team will also collect information how the 
provision on progressive access to category 
A driving licences affected the costs and 
administrative burden for national authorities 
and driving schools and instructors. 

126 

 
 
 
 
 
Sub-question 

Assessment / Judgement 
criteria 

Indicators  

Data sources  

Analytical approach 

•  Costs estimation for citizens for 
obligatory theoretical and 
practical course in professional 
driving school to obtain a driving 
licence 

•  Reports and studies, e.g. Delhaye, A., Marot, L. (2015), Training, 
testing and licencing, Deliverable 1 of the EC/MOVE/C4 project 
RIDERSCAN (Annex 2: User Survey – Feedback from European 
riders on the 3DLD implementation - Chapter 3.4. Opinion about the 
new licence scheme).  

•  Targeted survey with national driving licence authorities, drivers' 
associations and drivers school associations, road safety and road 
users' associations / civil society and their members, road transport 
associations and industry associations 

•  Targeted interviews with selected stakeholders 

•  Open Public Consultation 

•  Administrative burden for 

national administrations to apply 
for the category A driving licence 

•  Reports and studies: e.g. European Commission (2017), 
Implementation study: Annex 5: Survey results regarding 
modification of driving licence categories. 

•  Targeted survey with national driving licence authorities, drivers' 
associations and drivers school associations, road safety and road 
users' associations / civil society and their members, road transport 
associations 

•  Targeted interviews with selected stakeholders 

•  Open Public Consultation 

127 

 
Sub-question 

Assessment / Judgement 
criteria 

Indicators  

Data sources  

Analytical approach 

•  Administrative burden for driving 
schools and instructors to extend 
the curricula of driving schools as 
linked to upgrading training, 
testing for category A driving 
licences 

•  Reports and studies: e.g. European Commission (2017), 
Implementation study: Annex 5: Survey results regarding 
modification of driving licence categories. 

•  Targeted survey and interviews with driver's associations and drivers 

school associations 

EQ 9.3.2: What have been 
the benefits and other 
impacts of the introduction 
of progressive access to 
category A driving licences? 

EQ 9.3.2: Benefits and other 
impacts of the introduction 
of progressive access to 
category A driving licences.  

•  Road safety trends (e.g. 

•  Findings and data sources under EQ1.1 on trends of road traffic 

motorcycles involved in road 
fatalities and/or serious injuries)  

accidents 

•  Reports and studies: e.g. WHO (2018), Global status report on road 

safety; FEMA (2016), Motorcycle Safety and Accidents in Europe - a 
summary report.  

Comparison of road safety data trends (road 
fatalities and/or serious injuries) for 
motorcycle road user category with the total 
road safety trends will allow us to assess 
how much provisions of the directive (in 
particular, the introduction of progressive 
access to category A driving licences) 
affecting motorcycle riders have contributed 
to improved road safety trends. The approach 
is further described in chapter 5.4. 

•  Trends in progressive access 
compared to direct access to 
category A driving licences  

•  Reports and studies: e.g. Delhaye, A., Marot, L. (2015), A European 

Scanning Tour for Motorcycling Safety, Final Report of the 
EC/MOVE/C4 project RIDERSCAN: Chapter 2.2. Improving access 
to PTWs; ACEM Industry Report (2015), Chapter 4: The economics 
of the motorcycle sector and ACEM statistical release. 

Based on the desk and field research, the 
study team will identify the number of EU 
citizens opting for progressive access as 
compared to a direct access to category A 
driving licences (to the extent that such data 
is available).  

•  Targeted survey with national driving licence authorities, drivers' 
associations and drivers school associations, road transport 
associations 

The aim of the assessment is to identify 
whether progressive access is a popular 
choice for young and novice riders. 

•  Targeted interviews with selected stakeholders 

128 

 
 
 
 
Sub-question 

Assessment / Judgement 
criteria 

Indicators  

Data sources  

Analytical approach 

•  Level of impact of the 

introduction of progressive access 
to category A driving licences on 
road safety of young and novice 
drivers 

•  Open Public Consultation 

•  Reports and studies: e.g. European Commission (2017), Study on 
driver training, testing and medical fitness: Chapter 5: Graduated 
access to higher motorcycle categories; Christie (2014), A Discussion 
Paper on Elements of Graduated Licensing Systems for Motorcycle 
Riders; ITF (2015), Improving Safety for Motorcycle, Scooter and 
Moped Riders: Chapter 5: Countermeasures addressing road user 
behaviour (sub-chapter: Licencing, Training and Education); 
Delhaye, A., Marot, L. (2015), A European Scanning Tour for 
Motorcycling Safety, Final Report of the EC/MOVE/C4 project 
RIDERSCAN.  

•  Targeted survey with national driving licence authorities, drivers' 
associations and drivers school associations, road safety and road 
users' associations / civil society and their members, road transport 
associations, industry associations, insurance companies 

•  Targeted interviews with selected stakeholders 

•  Open Public Consultation 

Based on the desk and field research, the 
study team will assess the trends of road 
safety for young and novice riders as 
compared to the general road safety trends in 
order to assess, whether the provisions of the 
directive affecting young and novice drivers 
have led to positive road safety trends. 

•  Level of impact of the 

introduction of progressive access 
to category A driving licences on 
driver education and training 
curricula 

•  Reports and studies: e.g. Christie (2014), A Discussion Paper on 
Elements of Graduated Licensing Systems for Motorcycle Riders; 
European Commission (2017), Implementation study, Chapter: 
3.3.2.2 Categories A1/A2/A, Annex 5: Chapter Graduated access 
from A1 to A2 and from A2 to A and Chapter Access from A1 to A; 
Annex 2: User Survey – Feedback from European riders on the 
3DLD implementation.  

Based on the desk and field research, the 
study team will assess the changes in training 
obligations due to the introduction of 
progressive access to category A. 

129 

 
 
Sub-question 

Assessment / Judgement 
criteria 

Indicators  

Data sources  

Analytical approach 

•  Targeted survey with national driving licence authorities, drivers' 
associations and drivers school associations, road safety and road 
users' associations / civil society and their members, road transport 
associations 

•  Targeted interviews with selected stakeholders 

•  Open Public Consultation 

EQ 9.4: Establishing the EU driving licence network (RESPER)? 

EQ 9.4.1: What have been 
the costs of RESPER? 

EQ 9.4.1: Costs of RESPER 

•  Costs of RESPER for the 
European Commission 

•  Targeted interviews with the European Commission 

Based on the desk and field research, the 
study team will assess the costs of RESPER 
for national authorities (if any) and the EU 
institutions.  

•  Costs of RESPER for national 

authorities 

•  Reports and studies: e.g. European Commission (2016), Evaluation 
Study on the Application of directive 2011/82/EU Facilitating the 
Cross-Border Exchange of Information on Road Safety Related 
Traffic Offences 

•  Targeted survey and interviews with national driving licence 

authorities  

EQ 9.4.2: What have been 
the benefits and other 
impacts of RESPER? 

EQ 9.4.2: Benefits and other 
impacts of RESPER  

•  Number of Member States 

•  Findings and data sources under EQ2.7 on number of Member States 

connected to RESPER directly 
through national database or 
through EUCARIS 

connected to RESPER 

The aim of this assessment is to analyse all 
benefits and impacts of RESPER, including 
reduction of administrative burden for 
national authorities. 

130 

 
 
 
Sub-question 

Assessment / Judgement 
criteria 

Indicators  

Data sources  

Analytical approach 

This analysis will lead to a conclusion, 
whether RESPER brings more benefits than 
disadvantages and whether RESPER related 
costs are justified. 

•  Change in the administrative 

•  Reports and studies: e.g. European Commission (2017), 

burden for national authorities and 
citizens 

•  Level of information quality and 
reliability accessed through 
RESPER by national authorities 

Implementation study, Table 8.13: Overview of the effects of 
RESPER on administrative burden for citizens, Table 8.14: Overview 
of information that a citizens needs to provide besides the 
information accessed through RESPER, Table 8.15: Overview of the 
effects of RESPER on the costs for citizens, Table 8.15: Overview of 
the effects of RESPER on the costs for citizens.  

•  Targeted survey and interviews with national driving licence 

authorities 

•  Reports and studies: e.g. European Commission (2017), 

Implementation study, Table 7.7: Overview of how satisfied the 
Member States are with the SDLN service in RESPER, Table 7.10: 
Overview of how satisfied the Member States are with the GDLD 
service in RESPER, Table 7.13: Overview of how satisfied the 
Member States are with the NDLS service in RESPER, Table 7.16: 
Overview of how satisfied the Member States are with the secure 
messages service in RESPER. 

•  Change in number of fraud cases 
since the introduction of RESPER 

•  Reports and studies: e.g. European Commission (2017), 

Implementation study, Annex 8: Table 8.4: Overview of the effects 
of RESPER on driving licence fraud, Table 8.5: Overview of the 
effects of RESPER on driving licence fraud in specific situations 

•  Targeted survey and interviews national driving licence authorities  

EQ 9.5: How do the above costs compare to the benefits (EQ 10.1 – EQ 10.4) established? Which stakeholder groups had to deal with which costs, and which benefitted from the rules? 

131 

 
 
 
 
Sub-question 

Assessment / Judgement 
criteria 

Indicators  

Data sources  

Analytical approach 

EQ 9.5.1: How do the costs 
of selected provisions of the 
directive (single model 
licence, uniform driving 
licences, progressive access, 
RESPER) compare to their 
benefits? 

EQ 9.5.1: Comparison of 
costs and benefits of selected 
provisions of the directive 
(single model licence, 
uniform driving licences, 
progressive access, 
RESPER) 

•  Costs and benefit assessments 

•  Findings under EQ 9.1 – EQ 9.4 

including for specific stakeholder 
groups (from EQ 10.1 – EQ 10.4)  

The costs associated with the implementation 
of the directive will be compared to the 
benefits. 

EQ 10: Are there significant differences in costs between MSs and what is causing them? 

EQ 10.1: Differences in 
costs between Member 
States are significant. 

EQ 10.2: What have been 
the causes of the significant 
cost differences across the 
Member States? 

EQ 10.1: Differences in 
costs of selected provisions 
of the directive (single 
model licence, uniform 
driving licences, progressive 
access, RESPER) between 
the Member States are 
significant. 

EQ 10.2: Causes of the 
significant cost differences 
of selected provisions of the 
directive (single model 
licence, uniform driving 
licences, progressive access, 
RESPER) across the 
Member States 

•  Costs per Member State 

•  Findings under EQ 9.1 – EQ 9.4 

To the extent data is made available, the 
study will assess the differences in costs 
between Member States identified under EQ 
9.1 – EQ 9.4 and make a conclusion on 
causes of cost differences. 

The latter conclusion will be based on the 
results of planned consultation activities. 

•  Causes of costs for different cost 
categories (types of costs, as 
defined in EQ11.1) 

•  Targeted survey and interviews with national driving licence 

authorities, drivers' associations and drivers school associations 

•  Targeted survey and interviews national driving licence authorities  

EQ11: Is there a potential for simplification and reduction of regulatory burden caused by the directive, for instance through further digitalisation or better exploiting potential synergies with other travel documents 
within the Schengen area? 

132 

 
 
 
Sub-question 

Assessment / Judgement 
criteria 

EQ11.1: Has the directive 
led to any unnecessary 
complexities and regulatory 
burden? 

EQ11.1: Unnecessary 
complexities and regulatory 
burden caused by the 
directive 

Indicators  

Data sources  

Analytical approach 

•  Processes, procedures, activities 
linked to the directive's objectives 
that impose unnecessary 
complexities for different 
stakeholder groups (e.g. renewing 
driving licence procedures, time 
and required documentation for 
requesting a driving licence, 
medical checks, administrative 
validity periods, etc.) 

•  Findings from other criteria, particularly in terms of effectiveness of 
the directive (See EQ 2.1 on administrative burden) and in terms of 
relevance of the directive (See EQ 12-15) 

•  Reports and studies: e.g. European Commission (2017), 

Implementation study. 

•  Targeted survey and interviews with national driving licence 

authorities, drivers' associations and drivers school associations, road 
safety and road users' associations / civil society and their members  

Based on the desk and particularly field 
research as well as a Case study on Digital 
Driving Licence, the study team will assess 
whether there is a potential for simplification 
and reduction of regulatory burden caused by 
the directive, for instance through further 
digitalisation or better exploiting potential 
synergies with other travel documents within 
the Schengen area. 

•  Open Public Consultation 

EQ 11.2: Which are the 
opportunities for 
simplification of the 
directive and reduction of 
the regulatory burden? 

EQ 11.2: Opportunities for 
simplification of the 
directive and reduction of 
the regulatory burden  

•  Identified opportunities to 

simplify and reduce the costs in 
relation to (administrative) 
processes and procedures by 
means of digitisation 

•  Findings under EQ9: Has the directive resulted in any excessive 
costs/negative impacts findings from other criteria, particularly in 
terms of effectiveness of the directive (See EQ2.1 on administrative 
burden) and in terms of relevance of the directive (See EQ12-15) 

•  Reports and studies: e.g. European Commission (2017), 

Implementation study: 3.1.2.6 Administrative burden for public 
administration: storage and delivery and Table 3.4: Data storage and 
transfer before & after implementation of the third driving licence 
directive; EReg (2016), Improving Registration & Licencing Services 
through Digital Service Channels - Final Report. 

•  Case study on Digital Driving Licence 

•  Targeted survey and interviews with national driving licence 

authorities, drivers' associations and drivers school associations, road 

133 

 
Sub-question 

Assessment / Judgement 
criteria 

Indicators  

Data sources  

Analytical approach 

safety and road users' associations / civil society and their members  

•  Open public consultation 

EQ 11.3: Are there 
opportunities for 
simplification of the 
directive and reduction of 
the regulatory burden by 
means of enhancing 
synergies with other travel 
documents within the 
Schengen area? 

EQ 11.3: Opportunities for 
simplification of the 
directive and reduction of 
the regulatory burden by 
means of enhancing 
synergies with other travel 
documents within the 
Schengen area 

•  Identified opportunities to 

simplify and reduce the costs in 
relation to (administrative) 
processes and procedures by 
means of enhancing synergies 
with other travel documents 
within the Schengen area 

•  Findings under EQ9: Has the directive resulted in any excessive 
costs/negative impacts findings from other criteria, particularly in 
terms of effectiveness of the directive (See EQ2.1 on administrative 
burden) and in terms of relevance of the directive (See EQ12-15) 

•  Reports and studies: e.g. Implementation study (2017): 3.1.3.3 

Acceptance of driving licences as ID document. 

•  Targeted survey and interviews with national driving licence 

authorities, drivers' associations and driving school associations, road 
safety and road users' associations / civil society and their members.  

•  Open Public Consultation 

134 

 
 
Relevance 

Sub-question 

Assessment /Judgement criteria 

Indicators  

Data sources  

Analytical approach 

EQ 12: Do the objectives incorporated in the directive match the needs of today and the foreseeable future? 

EQ 12.1: Do the objectives of 
the directive address the 
current and future most 
significant needs in terms of 
legal considerations? 

EQ 12.1: The objectives of the directive 
address the current and future most 
significant needs in terms of legal 
considerations.  

The assessment will rely on a 
qualitative analysis of the current and 
future most significant needs and the 
extent to which they are addressed by 
the current provisions of the 
directive. This will be done both on 
the basis of desk research which will 
be triangulated with assessments 
made by stakeholders in the field 
research.  

•  Level of alignment/mismatch between 
the objectives of the directive and the 
current and foreseen most significant 
needs in terms of legal considerations 
(e.g. the concept of normal residence, 
digital driving licence, driving licence 
as proof of identity)) 

•  Reports, studies, relevant legislation: e.g. European 

Commission (2017), Implementation study (conclusions 
and recommendations); CIPTEC (September 2018), D1.1: 
Report on major market trends, the effect of societal 
trends on market and their influence on public transport 
(Chapter 7: Legal changes); Joint Research Centre (2019), 
The future of road transport - Implications of automated, 
connected, low-carbon and shared mobility.   

•  Extent to which current and arising 
legal challenges are addressed by the 
directive (e.g. in terms of technological 
advances, e.g. driverless vehicles, ride 
sharing, cooperative intelligent 
transport systems, eco-driving 
requirements, etc.)  

•  Targeted survey with national driving licence authorities, 
drivers' associations and drivers school associations, road 
users' associations / civil society and their members, road 
transport associations and industry associations  

•  Targeted interviews with selected stakeholder groups 

•  Open public consultation  

•  Level of flexibility of the directive to 
address the future identified needs 

•  Case study 2 - Digital driving licence and Case study 3 - 

Accompanied driving 

135 

 
 
 
 
Sub-question 

Assessment /Judgement criteria 

Indicators  

Data sources  

Analytical approach 

EQ 12.2: Do the objectives of 
the directive address the 
current and foreseen most 
significant needs in terms of 
social developments? 

EQ 12.2: The objectives of the directive 
address the current and foreseen most 
significant needs in terms of social 
developments. 

•  Level of alignment/mismatch between 
the objectives of the directive and the 
current and foreseen most significant 
needs in terms of social advances (e.g. 
progressive access to categories, 
ageing population) 

•  Level of flexibility of the directive to 
address social needs (e.g. socially 
inclusive mobility) 

•  Reports, studies, relevant legislation: e.g. European 
Commission (2017), Implementation study (chapter 
3.2.2.5 Medical checks upon renewal information related 
to ageing population); CIPTEC (2018), D1.1: Report on 
major market trends, the effect of societal trends on 
market and their influence on public transport (chapter 4: 
Social Changes); Institute of Transport Economics 
Norwegian Centre for Transport Research (2019), How 
will social trends impact transport?; European 
Commission (2017), Study on driver training, testing and 
medical fitness (chapter 3.5.1 age limits, chapter 8).  

•  Targeted survey with national driving licence authorities, 
drivers' associations and drivers school associations, road 
users' associations / civil society and their members, road 
transport associations and industry associations  

•  Targeted interviews with selected stakeholder groups 

•  Open public consultation  

•  Case study 3 - Accompanied driving 

136 

 
 
Sub-question 

Assessment /Judgement criteria 

Indicators  

Data sources  

Analytical approach 

EQ 12.3: Do the objectives of 
the directive address the 
current and foreseen most 
significant needs in terms of 
adaptation to technical 
progress? 

EQ 12.3: The objectives of the directive 
address the current and foreseen most 
significant needs in terms of adaptation 
to technical progress. 

•  Level of alignment/mismatch between 
the objectives of the directive and the 
current and foreseen most significant 
needs in terms of these technological 
advances (e.g. automatic transmission, 
active and passive safety features, 
alternative fuel vehicles, digital driving 
licence, automated driving, intelligent 
transport systems, clean transport 
technologies, car-sharing schemes, 
technology for motorcycles, including 
additional safety features ABS braking 
systems since 2016, etc.) 

•  Level of flexibility of the directive to 

address the identified needs 

•  Reports, studies, relevant legislation: e.g. European 
Commission (2017), Implementation study (chapter 
3.3.2.7 Electromobility and other forms of alternative 
propulsions); CIPTEC (2018), D1.1: Report on major 
market trends, the effect of societal trends on market and 
their influence on public transport (chapter 5: 
technological changes); Joint Research Centre (2019), The 
future of road transport - Implications of automated, 
connected, low-carbon and shared mobility; Joint 
Research Centre (2018), Electric vehicles in Europe from 
2010 to 2017: is full-scale commercialisation beginning?; 
European Environmental Agency (2016), Electric vehicles 
in Europe; Zagorskas and Burinskiene (2019), Challenges 
Caused by Increased Use of E-Powered Personal Mobility 
Vehicles in European Cities.  

•  Targeted survey with national driving licence authorities, 
drivers' associations and drivers school associations, road 
users' associations / civil society and their members, road 
transport associations and industry associations  

•  Targeted interviews with selected stakeholder groups 

•  Open public consultation  

•  Case study 2 - Digital driving licence and Case study 3 - 

Accompanied driving 

EQ 13: Are the minimum age limits established in the directive appropriate for current social needs? 

137 

 
 
Sub-question 

Assessment /Judgement criteria 

Indicators  

Data sources  

Analytical approach 

EQ 13.1: Do the minimum 
age limits in the directive 
address the current social 
needs of the Member States? 

EQ 13.1: The minimum age limits in 
the directive address the current social 
needs of the Member States. 

•  Variations in age limits applicable 

•  Reports, studies, relevant legislation: e.g. European 

across Member states 

Commission (2017), Implementation study (Table 5.2 
comparison of minimum age for obtaining categories 
A1/A2/A before and after the implementation of the 
directive); European Commission (2017), Study on driver 
training, testing and medical fitness (conclusions and 
recommendations).   

•  Level of alignment/ mismatch between 
the minimum age limits in the directive 
with social needs in different Member 
States and need for safe driving  

•  Findings under EQ12.3 on mapping on the most 

significant needs in terms of social developments (e.g. 
socially inclusive mobility) 

The assessment will rely both on 
evidence on the age limits and the 
levels of road safety to try to assess 
whether the age limits are appropriate 
as well as stakeholders perceptions.  

•  Findings under EQ 9.2.2 on negative impact of the 
harmonisation of age limits, driving licence validity 
periods and the exceptions 

•  Targeted interviews with selected stakeholder groups 

EQ 14: To what extent are all the types of existing or newly developed vehicles covered by the directive, given new mobility solutions such as micro mobility and electric bicycles and scooters? Are there significant differences 
among Member States or among age groups? 

EQ 14.1: To what extent are 
existing or newly developed 
vehicles covered by the 
directive? 

EQ 14.1: Extent to which the existing 
or newly developed vehicles are 
covered by the directive. 

•  Practices in relation to road users of 
new mobility solutions in Member 
States (number of Member States that 
introduced new mobility solutions in 
legislation, requirements on age 
limitation) 

•  Reports, studies: Joint Research Centre (2019), The future 
of road transport - Implications of automated, connected, 
low-carbon and shared mobility; European Commission 
(2017), Implementation study (chapter 3.3.2.7 
Electromobility and other forms of alternative 
propulsions); Zagorskas and Burinskiene (2019), 
Challenges Caused by Increased Use of E-Powered 
Personal Mobility Vehicles in European Cities.  

The analytical approach will rely on a 
qualitative analysis of the extent to 
which the directive's provisions cover 
newly developed vehicles and/or the 
extent to which these are covered at 
the national level. This will be 
complemented with evidence from 
stakeholders' assessments of new 
mobility solutions that should be 

138 

 
 
 
 
 
 
Sub-question 

Assessment /Judgement criteria 

Indicators  

Data sources  

Analytical approach 

•  Findings under EQ 12.4 on mapping of the current and 
foreseen most significant needs in terms of adaption to 
technical progress 

covered by the directive.  

•  Targeted survey with national driving licence authorities, 
drivers' associations and drivers school associations, road 
users' associations / civil society and their members, road 
transport associations and industry associations 

•  Targeted interviews with selected stakeholder groups 

•  Open public consultation 

•  Issues related to national legislation on 
new categories of vehicles in those 
Member States that introduced e-
scooters, electric bicycles and other 
micro mobility solutions in their 
national legislation 

•  Targeted survey with national driving licence authorities, 
drivers' associations and drivers school associations, road 
users' associations / civil society and their members, road 
transport associations and industry associations 

•  Targeted interviews with selected stakeholder groups 

•  Open public consultation 

•  Reports, studies: Joint Research Centre (2019), The future 
of road transport - Implications of automated, connected, 
low-carbon and shared mobility; European Commission 
(2017), Implementation study (chapter 3.3.2.7 
Electromobility and other forms of alternative 
propulsions); Zagorskas and Burinskiene (2019), 
Challenges Caused by Increased Use of E-Powered 

•  Level of flexibility of the directive to 
accommodate new road users such as 
electric bicycle and e-scooter riders 

139 

 
 
 
 
Sub-question 

Assessment /Judgement criteria 

Indicators  

Data sources  

Analytical approach 

Personal Mobility Vehicles in European Cities.  

•  Targeted survey with national driving licence authorities, 
drivers' associations and drivers school associations, road 
users' associations / civil society and their members, road 
transport associations and industry associations 

•  Targeted interviews with selected stakeholder groups 

•  Open public consultation 

EQ 15: To what extent are the provisions on driving licence renewal adapted to demographic trends such as an ageing population? 

EQ 15.1: Are the provisions 
on driving licence renewal in 
the directive adapted to 
demographic trends? 

EQ 15.1: Provisions on driving licence 
renewal in the directive are adapted to 
demographic trends. 

•  Trends in road traffic accidents 
according to age groups 

•  Findings under EQ 1.1 on trends of road traffic accidents 

•  Practices in Member States related to 
renewal of driving licences (e.g. 
frequency of driving licence renewal 
according to the age of the population, 
frequency of vision screening, medical 
questionnaire, traffic fatalities 
according to age group (above 65) / 
elderly road traffic fatalities) 

•  Reports, studies: e.g. European Commission, (2015), 

Older Drivers (report); Traffic Safety Basic Facts 2017333; 
European Commission (2017), Implementation Report 
(chapter 3.2.2.5 Medical checks upon renewal 
(information related to ageing population); European 
Commission (2017), Study on driver training, testing and 
medical fitness (chapter 3.5.1 Age limits) 

•  Findings under EQ 12.3 on mapping on the most 

This assessment will firstly provide 
quantifiable results on road safety 
trends for older generations. The 
approach is aligned with the baseline 
methodology. 

Based on the existing research and 
additional field research, the study 
team will map practices related to 
driving licence renewal procedures in 
different Member States in order to 
assess, whether relevant national 
legislations take into consideration 
demographic trends. These results 

333   https://ec.europa.eu/transport/road_safety/sites/roadsafety/files/pdf/statistics/dacota/bfs2017_main_figures.pdf  

140 

 
 
 
                                                           
Sub-question 

Assessment /Judgement criteria 

Indicators  

Data sources  

Analytical approach 

will underpin the assessment of 
flexibility of the directive, as 
perceived by various stakeholders, to 
accommodate demographic trends at 
EU level. 

significant needs in terms of social developments 

•  Targeted survey with national driving licence authorities, 
drivers' associations and drivers school associations, road 
users' associations / civil society and their members, road 
transport associations and industry associations 

•  Targeted interviews with selected stakeholder groups 

•  Open public consultation 

•  Reports, studies: e.g. European Commission (2017), 

Implementation study (chapter 3.2.2.5 Medical checks 
upon renewal (information related to ageing population, 
chapter: Limited administrative validity periods for Group 
1 and Group 2 drivers); European Commission (2017), 
Study on driver training, testing and medical fitness 
(chapter 3.5.1 age limits, chapter 8. Requirements on 
medical fitness to drive) 

•  Findings under EQ 12.3 on mapping on the most 
significant needs in terms of social developments 

•  Targeted survey with national driving licence authorities, 
drivers' associations and drivers school associations, road 
users' associations / civil society and their members, road 
transport associations and industry associations 

•  Targeted interviews with selected stakeholder groups 

•  Level of alignment of the provisions on 
driving licence renewal in the directive 
with demographic trends (e.g. age-
based driver screening policies, 
requirements on medical assessment 
according to age groups, requirements 
on licence renewal according to age 
groups, methods used for the drivers' 
assessment and driver fitness) and 
needs 

141 

 
 
 
Sub-question 

Assessment /Judgement criteria 

Indicators  

Data sources  

Analytical approach 

•  Open public consultation 

•  Level of flexibility of the directive's 

objectives to accommodate 
demographic trends in Member States 

•  Targeted survey with national driving licence authorities, 
drivers' associations and drivers school associations, road 
users' associations / civil society and their members, road 
transport associations and industry associations 

•  Targeted interviews with selected stakeholder groups 

•  Open public consultation 

142 

 
 
 
 
 
Coherence 

Sub-question 

Assessment /Judgement criteria 

Indicators  

Data sources  

Analytical approach 

EQ 16: To what extent are the provisions of the directive coherent and consistent with one another? Are there any overlaps, contradictions or inconsistencies? 

EQ 16.1: Are the provisions set out 
in the directive internally consistent 
and coherent? 

EQ 16.1: The provisions set out in the 
directive are internally consistent and 
coherent. 

•  Complementarities, overlaps and contradictions 
between the provision on the new model licence 
(Art. 1) and anti-forgery measures (Art. 2)  

•  Complementarities, overlaps and contradictions 
between the provision on anti-forgery measures 
(Art. 2) with the functionalities of RESPER 
(Art. 15) 

•  Complementarities, overlaps and contradictions 
between provisions with regards to driving 
skills (Annex IV) and provisions on mandatory 
medical checks (Art. 7) and with the provision 
on harmonisation of categories (Art. 14) 

•  Complementarities, overlaps and contradictions 
between the provision on harmonisation of 
categories (Art. 14) and the provision on 
mandatory medical checks (Art. 7) 

•  Reports and studies: e.g. European 

Commission (2017), Implementation 
study: chapter 4.2.3 Harmonised 
administrative validity periods and 
medical checks and recommendations.  

•  Other desk research: e.g. Feedback on 
the roadmap on Driving Licence rules 
(2019)334 ; infringement procedures of 
the directive (e.g. published by the 
European Commission; collected 
through Task 4). 

Based on the desk research, the study 
team will assess whether the 
provisions of the directive are coherent 
and consistent with one another and 
whether there are any overlaps, 
contradictions or inconsistencies. The 
approach to this assessment will rely 
on legal analysis of the provisions of 
the directive. 

EQ 17: Are there any inconsistencies/gaps/overlaps between the directive and other legislation at international level which has similar objectives, and in particular with the relevant international obligations of the Member States? 

334   https://ec.europa.eu/info/law/better-regulation/initiatives/ares-2019-5226562_en. 

143 

 
 
                                                           
Sub-question 

Assessment /Judgement criteria 

Indicators  

Data sources  

Analytical approach 

EQ 17.1: To what extent are there 
inconsistencies, gaps or overlaps 
between the directive and other 
legislation?  

EQ 17.1: There are no inconsistencies, 
gaps and overlaps between the directive 
and other legislation at international level 
with similar objectives. 

•  Inconsistencies, gaps and overlaps between the 
directive and international interventions with 
similar objectives related to: 

•  Findings from other evaluation 

questions on effectiveness (e.g. EQ1, 
EQ2.1, EQ2.3, EQ3, EQ7) 

Comparative analysis of the provisions 
of the directive and other legislation 
based on desk research and 
assessments by stakeholders. 

-  Road safety: e.g. with the International 
UNECE Transport Agreements and 
Conventions on road traffic335, legal 
instruments related to road transport and 
border crossing facilitation 

•  Legislation: policies and legislation at 
the international level with similar 
objectives as Directive 2006/126/EC 
and identify the objectives of these 
selected policies and legislation.  

-  Free movement: e.g. with the UNECE 
border crossing facilitation336, Geneva 
Convention on Road Traffic (1949)337, 
Vienna Convention on Road Traffic 
(1968)338 and its 2006 amendments339 

-  Fraud: e.g. with the Geneva Convention 
on Road Traffic (1949)340, and the 1971 
European Agreement Supplementing the 
Convention (Road Traffic)341, Vienna 

•  Studies by other organisations such as 

FIA348 and the UNECE349).  

•  Targeted survey and interviews with 
national competent authorities and 
members from UNECE 

The team is aware that the 
international obligations are much 
narrower in scope compared to the 
driving licence directive, therefore 
only any possible contradictions or 
overlaps will be assessed in the 
analysis. 

335   The UN Economic Commission for Europe (UNECE) guides the process of harmonizing and simplifying border crossing procedures for the various modes of inland transport and provides an overview of international UNECE 

Transport Agreements on its website http://www.unece.org/trans/conventn/legalinst.html 

336   https://www.unece.org/trans/international-agreements/transconventnlegalinst/list-of-agreements-for-tabs/border-crossing-facilitation-agreements-and-conventions.html 

337   https://treaties.un.org/pages/ViewDetailsV.aspx?src=TREATY&mtdsg_no=XI-B-1&chapter=11&Temp=mtdsg5&clang=_en 

338   https://treaties.un.org/Pages/ViewDetailsIII.aspx?src=TREATY&mtdsg_no=XI-B-19&chapter=11 

339   https://www.unece.org/fileadmin/DAM/trans/conventn/Conv_road_traffic_EN.pdf 

340   https://treaties.un.org/pages/ViewDetailsV.aspx?src=TREATY&mtdsg_no=XI-B-1&chapter=11&Temp=mtdsg5&clang=_en 

341   https://treaties.un.org/doc/Publication/UNTS/Volume%201731/volume-1731-A-17847-English.pdf 

144 

 
 
 
 
                                                           
Sub-question 

Assessment /Judgement criteria 

Indicators  

Data sources  

Analytical approach 

Convention on Road Traffic (1968)342 and 
its 2006 amendments343 

•  Open Public Consultation 

-  Testing and training of drivers and 
examiners: e.g. with the Geneva 
Convention on Road Traffic (1949)344, and 
the 1971 European Agreement 
Supplementing the Convention (Road 
Traffic)345, Vienna Convention on Road 
Traffic (1968)346 and its 2006 
amendments347 

•  Identified mechanisms to ensure exchanges and 
synergies between the directive and the 
identified legislation at the international level 

EQ 17.2: Are there any 
inconsistencies, gaps and overlaps 
between the directive and relevant 

EQ 17.2: There are no inconsistencies, 
gaps and overlaps between the directive 
and relevant international obligations of 

•  Inconsistencies, gaps, overlaps of the directive 
with key international obligations of the EU27 
Member States, aligned with the objectives 

•  Findings from other evaluation 

questions on effectiveness (e.g. EQ1, 

348   FIA (2017), Proposed amendment relating to driving permits in the 1968 road traffic convention, https://www.unece.org/fileadmin/DAM/trans/doc/2017/wp1/ECE-TRANS-WP1-2017-March-Presentation-3e.pdf 

349   United Nations, Main United Nations Road Transport Agreements, https://sustainabledevelopment.un.org/content/documents/1761Main%20UN%20Road%20Transport%20Agreements.pdf 

342   https://treaties.un.org/Pages/ViewDetailsIII.aspx?src=TREATY&mtdsg_no=XI-B-19&chapter=11 

343   https://www.unece.org/fileadmin/DAM/trans/conventn/Conv_road_traffic_EN.pdf 

344   https://treaties.un.org/pages/ViewDetailsV.aspx?src=TREATY&mtdsg_no=XI-B-1&chapter=11&Temp=mtdsg5&clang=_en 

345   https://treaties.un.org/doc/Publication/UNTS/Volume%201731/volume-1731-A-17847-English.pdf 

346   https://treaties.un.org/Pages/ViewDetailsIII.aspx?src=TREATY&mtdsg_no=XI-B-19&chapter=11 

347   https://www.unece.org/fileadmin/DAM/trans/conventn/Conv_road_traffic_EN.pdf 

145 

 
 
                                                                                                                                                                                                                                                                                                       
Sub-question 

Assessment /Judgement criteria 

Indicators  

Data sources  

Analytical approach 

international obligations of the 
Member States? 

the Member States 

regarding road safety, free movement, fraud, 
and drivers' training and education, i.e. with the 
Geneva Convention on Road Traffic (1949)350 
and the 1971 European Agreement 
Supplementing the Convention (Road 
Traffic)351, Vienna Convention on Road Traffic 
(1968)352 and its 2006 amendments353 

EQ2.1, EQ2.3, EQ3, EQ7, EQ17.1) 

•  Other desk research: e.g. international 
legislation and international obligations 
of the Member States. 

•  Targeted survey and interviews with 
national competent authorities. 

•  Identified mechanisms to ensure exchanges and 
synergies between the directive and relevant 
international obligations of the Member States  

•  Open Public Consultation 

EQ 18: To what extent is the directive coherent with: 

EQ 18.1: other EU legislation in the area of road safety, and in particular with regards to their scope of application 

EQ 18.1: Is the directive designed in 
a way to support the objectives and 
minimise overlaps / ensure synergies 

EQ 18.1: The directive is designed in a 
way to support the objectives and 
minimise overlaps / ensure synergies 

•  Level of synergies between the directive 
(objectives, provisions and scope of 
application) and directive 2015/413 on cross-

•  Findings from other evaluation 

questions on effectiveness (e.g. EQ1, 
EQ2.1, EQ2.3, EQ3, EQ7) on the 

Comparative analysis of the provisions 
of the directive with other relevant 
legislation based on desk research and 

350   https://treaties.un.org/pages/ViewDetailsV.aspx?src=TREATY&mtdsg_no=XI-B-1&chapter=11&Temp=mtdsg5&clang=_en 

351   https://treaties.un.org/doc/Publication/UNTS/Volume%201731/volume-1731-A-17847-English.pdf 

352   https://treaties.un.org/Pages/ViewDetailsIII.aspx?src=TREATY&mtdsg_no=XI-B-19&chapter=11 

353   https://www.unece.org/fileadmin/DAM/trans/conventn/Conv_road_traffic_EN.pdf 

146 

 
 
 
 
 
                                                           
Sub-question 

Assessment /Judgement criteria 

Indicators  

Data sources  

Analytical approach 

with other EU legislation in the area 
of road safety? 

with other EU legislation in the area of 
road safety 

border exchange of information on road-safety 
related traffic offenses354 

•  Level of synergies between the directive 
(objectives, provisions and scope of 
application) and directive 2003/59/EC on the 
initial qualification and periodic training of 
drivers of certain road vehicles for the carriage 
of goods or passengers357 

•  Level of consistency of the minimum age 
requirement in Directive 2003/59/EC on 
training of professional drivers and Directive 
2006/126/EC 

stakeholders' assessments.  

extent to which issues are detected 
regarding the implementation of the 
directive, and whether these have a 
connection to requirements in the key 
EU legislation in the area of road safety 

•  Other desk research: e.g. Directive 
2015/413 facilitating cross-border 
exchange of information on road-
safety-related traffic offences355, 
Directive 2003/59/EC and Directive 
2006/126/EC; Feedback on the 
roadmap on Driving Licence rules 
(2019)356.  

•  Targeted survey and interviews with 
Member State authorities, road safety 
and road users' associations. 

•  Stakeholders perceptions on synergies/ overlaps 
and coherence of the directive with a sample of 
another EU legislation  

•  Targeted survey and interviews with 
Member State authorities and road 
safety and road users' associations 

354   https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX%3A32015L0413 

355   European Commission, EU Road Safety Policy, https://ec.europa.eu/transport/road_safety/specialist/policy_en 

356   https://ec.europa.eu/info/law/better-regulation/initiatives/ares-2019-5226562_en. 

357   https://eur-lex.europa.eu/legal-content/EN/ALL/?uri=CELEX%3A32003L0059 

147 

 
 
 
 
                                                           
Sub-question 

Assessment /Judgement criteria 

Indicators  

Data sources  

Analytical approach 

•  Open Public Consultation 

EQ 18.2: Other EU transport legislation, in particular in the areas of automated driving and digitalisation policies? Are there any overlaps, gaps or inconsistencies? Are there any complementarities/synergies? 

EQ 18.2: Is the directive designed in 
a way to support the objectives and 
minimise overlap / ensure synergies 
with other EU transport legislation, 
particularly in the areas of 
automated driving and digitalisation 
policies? 

EQ 18.2: The directive is designed in a 
way to support the objectives and 
minimise overlap / ensure synergies with 
other EU transport legislation, 
particularly in the areas of automated 
driving and digitalisation policies 

•  Synergies between the directive (objectives, 
provisions and scope of application) and the 
Cooperative, connected and automated mobility 
initiative (CCAM)358 in the framework of the 
European Strategy on Cooperative Intelligent 
Transport Systems (C-ITS) 

•  Level of synergies between the directive 
(objectives, provisions and scope of 
application) and the Digital Transport policy 
and framework360 

Comparative analysis of the provisions 
of the directive with other EU 
transport legislation, in particular in 
the areas of automated driving and 
digitalisation policies based on desk 
research and stakeholders' 
assessments.  

•  Findings from other evaluation 

questions on effectiveness (e.g. EQ1, 
EQ2.1, EQ2.3, EQ3, EQ7) on the 
extent to which issues are detected 
regarding the implementation of the 
directive, and whether these have a 
connection to requirements in the key 
other EU transport legislation  

•  Other desk research: e.g. EU transport 
legislation and initiatives; Feedback on 
the roadmap on Driving Licence rules 
(2019)359. 

358   https://ec.europa.eu/transport/themes/its/c-its_en 

359   https://ec.europa.eu/info/law/better-regulation/initiatives/ares-2019-5226562_en. 

360   https://www.consilium.europa.eu/en/press/press-releases/2017/12/05/digitalisation-of-transport-council-conclusions/ 

148 

 
 
 
 
 
 
 
 
                                                           
Sub-question 

Assessment /Judgement criteria 

Indicators  

Data sources  

Analytical approach 

•  Stakeholders perceptions on synergies /overlaps 
and coherence of the directive with the sample 
of other EU transport legislation  

•  Targeted survey and interviews with 
Member State authorities, road safety 
and road users' associations and 
industry associations 

•  Open Public Consultation 

EQ 18.3: Other EU legislation such as motor vehicle type-approval legislation, the Digital Single Market and e-Government initiatives in relation to digitalisation? 

EQ 18.3: Is the directive designed in 
a way to support the objectives and 
minimise overlap / ensure synergies 
with other EU legislation related to 
motor vehicle type-approval 
legislation, the Digital Single 
Market and e-Government 
initiatives in relation to 
digitalisation? 

EQ 18.3: The directive is designed to 
support the objectives and minimise 
overlap / ensure synergies with EU 
legislation related to motor vehicle type-
approval, the Digital Single Market and 
e-Government initiatives in relation to 
digitalisation 

•  Level of synergies between the directive 
(objectives, provisions and scope of 
application) and the Regulation (EU) 2018/858 
of the European Parliament and of the Council 
of 30 May 2018 on the approval and market 
surveillance of motor vehicles and their trailers, 
and of systems, components and separate 
technical units intended for such vehicles361 

•  Findings from other evaluation 

questions on effectiveness (e.g. EQ1, 
EQ2.1, EQ2.3, EQ3, EQ7) on the 
extent to which issues are detected 
regarding the implementation of the 
directive, and whether these have a 
connection to requirements in the key 
other EU legislation  

Comparative analysis of the provisions 
of the directive with other EU 
legislation, such as motor vehicle type-
approval legislation, based on desk 
research and stakeholders' 
assessments.  

•  Level of synergies between the directive 
(objectives, provisions and scope of 
application) and the Regulation 167/2013 on the 
type-approval of tractors and Regulation 
168/2013 on the type-approval of motorcycles 

•  Other desk research: e.g. EU legislation 
related to e-Government initiatives and 
in relation to digitalisation;  

•  Feedback on the roadmap on Driving 

361   https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX%3A32018R0858 

149 

 
 
 
 
 
 
                                                           
Sub-question 

Assessment /Judgement criteria 

Indicators  

Data sources  

Analytical approach 

•  Level of synergies between the directive 
(objectives, provisions and scope of 
application) the Digital Single Market  

•  Level of synergies between the directive 
(objectives, provisions and scope of 
application) and e-Government initiatives in 
relation to digitalisation 

Licence rules (2019)362.  

•  Targeted surveys and interviews with 
Member State authorities (to retrieve 
examples of e-Government initiatives 
in relation to digitalisation) 

•   

EQ 19: What are the impacts of the observed internal/external inconsistencies/gaps/overlaps of the effectiveness? 

EQ 19.1: Have the observed 
inconsistencies/gaps/overlaps any 
negative impacts on the effectiveness 
of the directive? 

EQ 19.1: The observed 
inconsistencies/gaps/overlaps have 
some/no negative impacts on the 
effectiveness of the directive 

•  Level of impact of the identified 

inconsistencies, gaps and/or overlaps as part of 
EQ 16, EQ 17 and EQ 18 on the effectiveness 
of the directive in achieving the objectives 

•  Findings from the other evaluation 

questions on coherence (e.g. EQ16 – 
EQ18) 

•  Stakeholders' views and perception on the level 
of impact on the effectiveness of the directive 

•  Other desk research: e.g. selected EU 
legislation (mapping with scope of 
application).  

•  Targeted survey and interviews with 

selected stakeholders. 

•  Based on desk and especially field 
research, the study team will 
assess whether observed 
internal/external 
inconsistencies/gaps/overlaps 
have an impact on the 
effectiveness of the driving 
licence directive, as perceived by 
various stakeholders. 

Qualitative assessment of the types of 
impacts that gaps and overlaps 
between the directive and other 

362   https://ec.europa.eu/info/law/better-regulation/initiatives/ares-2019-5226562_en. 

150 

 
 
                                                           
Sub-question 

Assessment /Judgement criteria 

Indicators  

Data sources  

Analytical approach 

•  Open Public Consultation 

legislation have.  

EU added value 

Sub-question 

Assessment /Judgement criteria 

Indicators  

Data sources  

Analytical approach 

EQ 20: What are the benefits of intervening at EU level, over and above what could have been reasonably expected from MSs acting individually at regional, national or international level (notably through the UNECE structure)? 

EQ 20.1: The directive has 
brought benefits beyond what the 
Member States could achieve 
acting individually at national, 
regional and international level. 

EQ 20.1: Has the 
directive brought 
benefits beyond what 
the Member States 
could achieve acting 
individually at national, 
regional and 
international level? 

The findings on the extent to which the 
directive has reached its objectives in terms of 
road safety and free movement of persons will 
used to support the added value of the 
directive as compared to a scenario where no 
directive would have been adopted. This will 
be complemented with assessments by 
stakeholders from the field research on the 
benefits of the directive.  

•  Benefits achieved through the 

•  Findings from the effectiveness, efficiency and relevance criteria  

intervention at the EU level in the 
fields of road safety, free 
movement, fraud, driving skills and 
education, protection of (novice) 
drivers and others  

•  Benefits achieved at Member States 
level by having acted individually 
through the UNECE at the national, 
regional and/or international level 

•  Perception from Member States 
regarding whether (and where 
feasible, how much) the 
(hypothetical) absence of the 
directive could have affected road 

•  Other desk research: e.g. UNECE database, national legislation 

and policies, etc. 

•  Targeted survey and interviews with national driving licence 

authorities (national competent authorities), drivers associations 
and drivers school associations and road safety, road users' 
associations / civil society and their members and road transport 
associations  

151 

 
 
 
 
 
 
Sub-question 

Assessment /Judgement criteria 

Indicators  

Data sources  

Analytical approach 

safety in their countries 

•  Open Public Consultation 

•  Rating of the added value of the key 
provisions of the directive (by 
stakeholders and by evaluators)/ 
stakeholder assessment of the 
benefits  

•  Identified changes in the national 

processes, policies and/or initiatives 
due to synergies achieved through 
the directive 

EQ 21: How much actual value has been created, and what evidence is there in terms of order of magnitude of this added value? 

EQ 21.1: How much of 
the added value has 
been created through 
the implementation of 
the directive? 

EQ 21.1: Extent of the added 
value created through the 
implementation of the directive  

•  Level of contribution of the 

•  Findings from the effectiveness, efficiency and relevance criteria 

directive to free movement EU 
citizens as measured through 
effectiveness and efficiency 
questions and indicators, e.g. 
administrative burden and changed 
processes for renewing driving 
licence, harmonisation of the 
validity periods and the uniformed 
rules and requirements in costs for 
renewing driving licence 

•  Reports and studies: e.g. European Commission (2017), 

Implementation study: Table 4.8 overview of the effects of 
administrative validity periods on freedom of movement, table 
4.20 overview of future measures for improvement in the area of 
freedom of movement. 

•  Case study 1 - Methodology for establishing a causal link between 
the directive and its effects on road safety and free movement of 

The assessment will rely on evidence 
concerning the contribution of the directive to 
road safety and free movement of persons (i.e. 
dimensions of added value that can be 
quantified). This will be complemented with 
evidence from stakeholders assessments.  

152 

 
 
 
Sub-question 

Assessment /Judgement criteria 

Indicators  

Data sources  

Analytical approach 

citizens/drivers and quantifying them 

•  Targeted survey and interviews with national authorities, drivers' 
associations and drivers school associations, civil society and their 
members  

•  Level of contribution of the 

•  Findings from the effectiveness, efficiency and relevance criteria 

directive to road safety as measured 
through effectiveness and efficiency 
questions and indicators, e.g. trends 
in road traffic accidents, trends in 
instances of forgery / fraud, trends 
on the measures and harmonised 
rules related to drivers' education, 
driving examiners rules and medical 
checks   

•  Reports and studies: e.g. European Commission (2017), 

Implementation study: Table 4.22 overview of future measures for 
improvement in the area of road safety. 

•  Targeted survey and interviews with national authorities, drivers' 
associations and drivers school associations and Road safety and 
road users' associations  

•  Case study 1 - Methodology for establishing a causal link between 
the directive and its effects on road safety and free movement of 
citizens/drivers and quantifying them 

•  Number of instances of driving 
licence fraud and driving licence 
tourism  

•  Findings and data sources under EQ1.1 on trends in instances of 

driving licence fraud and driving licence tourism 

EQ 22: Would it have been possible to have the same results without the directive? 

EQ 22.1: To what 
extent the same results 

EQ 22.1: Extent to which the 
same results could have been 

•  Identified results achieved by the 
directive (i.e. for road safety, free 

•  Findings from the effectiveness, efficiency and relevance criteria  

As described above, this assessment will rely 
on evidence from effectiveness and efficiency 

153 

 
Sub-question 

Assessment /Judgement criteria 

Indicators  

Data sources  

Analytical approach 

could have been 
achieved without the 
directive? 

achieved without the directive 

movement of persons and forgery / 
fraud) at the national level 

•  Targeted survey and interviews with national authorities, drivers' 
associations and drivers school associations and Road safety and 
road users' associations  

criteria which will be complemented with 
stakeholder's assessments from the field 
research.  

•  Perception by stakeholders on 

•  Targeted survey and interviews with national authorities, EU 

institutions (DG MOVE), road safety and road users' associations, 
road transport association, industry associations and the UNECE 
(selection of members) 

•  Open Public Consultation 

whether (and maybe how much) the 
(hypothetical) absence of the 
directive would have affected road 
safety in their countries 

•  Perception by stakeholders on how 
the driving licence procedures 
would have progressed in their 
Member State (and beyond) without 
the directive  

•  Level of inconsistencies between 
Member States' policies before the 
implementation of the directive  

•  Targeted survey and interviews with national authorities, EU 

institutions (DG MOVE), road safety and road users' associations, 
road transport association, industry associations and the UNECE 
(selection of members) 

•  Open Public Consultation 

154 

 
 
 
 
 
Annex 4: Intervention logic 

155 

RESULTSUNINTENDED EFFECTSIMPACTSGENERAL objSPECIFIC objOPERATIONAL objINPUTSOUTPUTSEnhance road safetyFacilitate free movement for EU citizensReduce administrative burden for drivers,administrations and enforcement authorities Establish a single EU driving licence model and its mutual recognition by MS Facilitate the issue, renewal, exchange and replacement of driving licences when changing residence from one MS to anotherThe periodicity of medical checks for professional drivers is harmonisedRoad safety is improvedFree movement of EU citizens is facilitatedHarmonised rules to issue, renew, exchange and replace EU driving licences All new EU driving licences have the same administrative validityEstablish uniform driving licence rules and requirements Art. 2: Obligation for MS to mutually recognize licences issued by themArt. 3: Obligation for MS to adopt anti-forgery measures for DLArt. 7: Obligation for MS to issue driving licences with an administrative validity of 10 years (which may be increased up to 15 years)A single secure EU driving licence model is issued by all MSs and is mutually recognised. Paper cards are phased out and a plastic card with a microchip is introduced Enforcement authorities and drivers benefit from the reduction in driving licence fraud Road users benefit from safer driving by professional and non professional drivers   Harmonise and limit the administrative validity for all new licencesHarmonise the periodicity of medical checks for professional driversReduce the possibilities of driving licence fraud and “driving license tourism” Enhance the principle of progressive access as regards the most powerful motorcyclesArt. 7: Obligation for MS to issue licences only to those having passed a test of skill and behaviour and a theoretical test and have normal residence in their territoryArt. 6: Obligation for MS to follow harmonised staging and equivalences between categoriesArt. 4: Obligation for MS to establish acategory for MOPEDSand progressive access to category A driving licencesArt. 4: Obligation for MS to implement harmonised DL categories, vehicle definitions and minimum agesArt. 1: Obligation for MS to introduce a national DL based on a EU modelRaise the driving skills of non-professional and professional drivers Protect novice drivers Facilitate implementation and enforcement of DVL rules Harmonise the initial qualification and periodic training of driving examinersEstablish the principle of a single driving licence per person (1 holder, 1 licence)Ensure cooperation between MS by establishing the EU driving licence network (RESPER)Introduce a driving licence category for mopedsIntroduce the plastic card with a microchipArt. 7: Obligation for MS to ensure that no person holds more than one driving licence and to verify compliance with minimum standards of physical and mental fitness for driving for categories C and DArt. 10: Obligation for MS to require that driving examiners meet minimum standards for their work, including quality assurance and regular periodic trainingArt. 11: Obligation for MS to exchange and replace other MS driving licences of holders that have normal residence in their territoryArticle 15: Obligation for MS to provide mutual assistance and exchange information on the licences they have issued, exchanged, replaced, renewed or revoked using the EU driving licence network (RESPER)MSs require progressive access for issuing a category A driving licenceDriving examiners in all MS have the same initial qualification and periodic Only one EU driving licence is issued per personA new driving licence category for mopeds is introducedNovice drivers are more protected in terms of road safetyBetter law enforcement by national authorities  Citizens  benefit from improved transport security  Professional drivers working in the EU are protected from distortion of competition Novice drivers  face increased costs to obtain a driving licenceChanging residence from one MS to another is facilitated for driversAdministrationsand drivers  benefit from reduced administrative costsMore unlicenced novice driversEU driving licence network isset up and operationalAdministrations and enforcement bodies benefit from exchange of information 
 
 
Figure 1 Comparison of road accident fatalities per million population compared to targets (road accident fatalities per 
million population) 363 

Annex 5: Tables and graphics 

Source: evaluation support study based on CARE Data, CADaS Data, extracted 2020 

363   European countries before 1983, 10 MS and 18 non-MS from 1983-1985, 12 MS and 16 non-MS from 1986-1994, 15 MS and 13 non-MS from 1995-2003, 25 MS and 3 non-MS from 2004-2006, 27 MS and 1 non-MS from 

2007-2012, 28 MS from 2014-2018. 

156 

 
 
 
 
 
 
 
                                                           
Figure 2  Responses to the question "Question To what extent do you agree with the following statements concerning the 
added value of the directive?" 

Source: Survey with non-governmental stakeholders. 

157 

 
 
 
 
 
 
Table 1 Objectives, tools/measures and legal obligations imposed by the directive 

General 
objectives  

Specific 
Objectives 

Tools/measure 

Legal Provision 

Facilitate free 
movement  

Reduce 
administrative 
burden for 
drivers, 
administrations 
and enforcement 
authorities  

Establish 
uniform rules 
and 
requirements 

To  establish  a  single  EU  driving 
licence  model 
its  mutual 
recognition by Member States 

and 

To  introduce  the  plastic  card  with  a 
microchip 

Art. 1: Obligation to introduce a national driving licence based on a Community Model 

Art. 3: Obligation to adopt anti-forgery measures for driving licences 

the 

issue, 

facilitate 

To 
renewal, 
exchange  and  replacement  of  driving 
licences when changing residence from 
one Member State to another 

harmonise 

To 
the 
administrative  validity  for  all  new 
licences 

limit 

and 

Art. 2: Obligation to mutually recognise driving licences issued by the Member States 

Art. 4: Obligation to implement harmonised driving licence categories, vehicle definitions and minimum ages 

Art. 4: Obligation to establish a category for MOPEDS and progressive access to category A driving licences 

Art. 11: Obligation to exchange and replace other Member States’ driving licences of holders that have normal 
residence in their territory 

Art. 7: Obligation to issue driving licences only to those having passed a test of skill and behaviour and a 
theoretical test and have normal residence in their territory 

Art. 7: Obligation to issue driving licences with an administrative validity of 10 years (which may be increased up 
to 15 years) 

158 

 
 
 
 
 
 
 
 
 
 
 
 
Enhance road 
safety 

To  reduce 
possibilities 
driving 
fraud 
“driving 
tourism” 

the 
of 
licence 
and 
licence 

the 
raise 
To 
driving  skills  of 
non-professional 
and  professional 
drivers 

To  facilitate  the 
implementation 
and  enforcement 
of driving licence 
rules 

To establish the principle of a single 
driving licence per person (1 holder, 1 
licence) 

Art. 7: no person holds more than one driving licence, and a requirement to verify the compliance with minimum 
standards of physical and mental fitness for driving categories C. 

To harmonise the periodicity of 
medical checks for professional drivers 

Art.7 (3)  

To harmonise the initial qualification 
and periodic training of driving 
examiners 

Obligation of continuing compliance with the standards on medical fitness for professional drivers 
Art. 4: Obligation to establish a category for MOPEDS and progressive access to category A driving licences 

Art. 10: Obligation to require that driving examiners meet minimum standards for their work, including quality 
assurance and regular periodic training 

To enhance the principle of 
progressive access to more powerful 
motorbikes 
To foster cooperation between 
Member States by establishing the EU 
driving licence network (RESPER) 

Art.6 : Obligation to follow harmonised staging categories and equivalences between categories 
Art. 7 (1) (c)   
Obligation of Minimum 2 years’ experience on the lower category 

Article 15: Obligation to provide mutual assistance and exchange information on the licences they have issued, 
exchanged, replaced, renewed or revoked using the EU driving licence network (RESPER) 

To protect novice 
drivers  

Introduce a driving licence category 
for mopeds 

Art. 4: Obligation to establish a category for MOPEDS and progressive access to category A driving licences 

159 

 
 
 
 
 
 
 
 
 
 
 
 
Table 2 Methodology Structure 

Figure 2 Support Study Methodology Structure 

160 

 
 
 
 
Table  Administrative validity periods for A-B driving licence categories 

Table 3 Validity periods  

Category 

10 years 

15 years 

AM, A1, A2, A  Belgium, Bulgaria, Croatia, Czechia , Estonia, Hungary, Ireland, 
Italy,  Latvia,  Lithuania,  Luxembourg,  Malta,  the  Netherlands, 
Portugal, Romania, Slovenia, Spain, Sweden, United Kingdom 

Austria,  Cyprus,  Germany,  Denmark,  Finland,  France,  Greece, 
Iceland, Norway, Poland, Slovakia 

B, B1, BE 

Belgium, Bulgaria, Croatia, Czechia , Estonia, Hungary, Ireland, 
Italy,  Latvia,  Lithuania,  Luxembourg,  Malta,  the  Netherlands, 
Portugal, Romania, Slovenia, Spain, Sweden, United Kingdom 

Austria,  Cyprus,  Germany,  Denmark,  Finland,  France,  Greece, 
Iceland, Norway, Poland, Slovakia 

Source:  Based  on  the  results  from  the  targeted  survey  with  national  authorities  and  European  Commission  (2017),  The  implementation  of  Directive 
2006/126/EC on driving licences. Re-port drafted by Hasselt University, NTUA. 

Shorter administrative validity periods and limitations for novice  drivers are applied in several Member States. For categories A and B licences, as presented in  Table 0-1 below, 7 
Member  States  apply  either  shorter  validity  periods  or probation/trial  periods. The  limited  validity  period  is  usually  2-3  years.  Some  countries  have  a  two-phased  driving  licencing 
procedure. In Luxembourg, the candidates  for licences  A2 and B have to undergo additional training before  obtaining a permanent licence. For categories C and D, exceptions  and 
limitations for novice drivers are much more rarely imposed, as only in Norway and Ireland, there is a probational period or limited validity period for novice professional drivers which 
is less than the usual 5 years. 

In some countries, there are stricter rules applied to novice drivers. According to the national authorities in Austria, Bulgaria, Greece, Norway, Slovenia, Sweden and Belgium, novice 
drivers  are  automatically  subject  to  stricter  rules  (e.g.  in  terms  of  penal  measures,  demerit  points,  alcohol  limit,  additional  training).  For  example,  Belgium  applies  stricter  penal 
measures for certain traffic violations for novice drivers. Norway also applies stricter penalties for traffic offences. Slovenia applies stricter rules including a lower maximum number of 
penalty points, additional safety training, zero alcohol policy. Bulgaria applies the same limitations for novice drivers as for other drivers, but the maximum number of penalty points is 
lower for novice drivers. 

161 

 
 
 
 
Table 0-1 Shorter administrative validity periods for driving licences and other limitations concerning administrative validity periods when it comes to novice drivers 

Exemptions 

Countries 

Shorter  administrative  validity  period  for  category  AM,  A1, 
A2, B, B1, B 

•  France (3 years) 
•  Iceland (3 years for B category) 
•  Ireland (2 years) 
•  Lithuania (2-3 years) 
•  Luxembourg (2 years for categories A2 and B) 
•  Norway (2 years of probation period) 
•  Slovenia (2 years or until the age of 21 years)  

Shorter administrative validity period for category C, CE, C1, 
C1E, D, DE, D1, D1E 

•  Ireland (2 years) 
•  Norway (probation period) 

Shorter  administrative  validity  period  first  licence  issued  for 
categories C and D 

•  Ireland (2 years)  
•  Norway (probation period) 

Other 

•  Austria (stricter rules) 
•  Belgium (stricter penal measures for certain traffic violations) 
•  Germany (2 years' probation period)  
•  Netherlands (5 years for first issue of categories A and B) 
•  Sweden (trial period of 2 years) 

Source: Survey with national authorities. 

Concerning the limited administrative validity periods for drivers above 50 years, several national authorities impose exemptions or limitations. As presented below, 8 Member States 
and Norway apply shorter administrative validity periods for older drivers for categories A and B, whereas 6 Member states and Norway apply shorter administrative validity periods 
for category C and D. Furthermore, 13 Member States and Norway apply increased frequency of medical checks whereas 1 country requires refresher courses.  

162 

 
Table 0-2 

Are there any exceptions or limitations in your country concerning administrative validity periods when it comes to drivers above 50 years? 

Shorter 
administrative 
validity period for category 
AM, A1, A2, B, B1, BE 

administrative 
Shorter 
for 
period 
validity 
category  C,  CE,  C1, 
C1E, D, DE, D1, D1E 

Increased 
medical checks  

frequency  of 

Refresher courses 

Other measures 

additional 

No 
exceptions/ 
limitations 

•  Finland  
•  Greece 
•  Hungary 
•  Ireland 
•  Italy364 
•  Luxembourg 
•  Netherlands 
•  Norway 
•  Slovenia 

•  Austria 
•  Finland 
•  Ireland 
•  Norway 
•  Hungary 
•  Greece 
•  Poland 
•  Slovenia 

Source: Survey with national authorities. 

•  Austria 
•  Belgium 
•  Czechia 
•  Finland 
•  Estonia 
•  Greece 
•  Hungary 
•  Ireland 
•  Latvia 
•  Lithuania 
•  Luxembourg 
•  Netherlands 
•  Norway 
•  Slovenia 

•  Slovenia 

•  Germany 
•  Slovenia 

•  Croatia 
•  Cyprus 
•  Denmark 
•  France 
•  Iceland 
•  (Italy365) 
•  Romania 
•  Slovakia 
•  Slovenia 
•  Spain 
•  Sweden 

364   The Italian national authority did not specify under this question, whether there is a shorter validity period for categories A-B, however, it indicated so under one of its previous responses to the question (‘What is the current 
administrative validity period in your country for A and B driving licence categories?’). According to its reply, Italy has a different administrative validity period of categories A and B driving licences for older drivers. From 
the age of 70 years, the validity period is reduced to 3 years and from the age of 80 it is reduced to 2 years. 

365   Under another question, the Italian national authority indicated that the validity period for categories A-B is reduced to 3 years from the age of 70 years and from the age of 80 it is reduced to 2 years. 

163 

 
                                                           
The  conditions  for  renewing  driving  licences  after  expiry  of  administrative  validity  vary  across  Member  States.  As  presented  below,  7  Member  States  apply  the  examination  of 
minimum standards for physical and  mental training  for renewal of driving licences,  whereas other Member States apply other requirements ranging from renewed photos,  medical 
examination, self-declaration of physical fitness or re-testing.  

Table 0-3 Requirements and conditions for renewal of driving licences when the administrative validity period expires 

Examination of minimum standards for physical and mental training for 
renewal of category AM, A1, A2, B, B1, BE licences 

Other 

•  Bulgaria 
•  Estonia 
•  Greece 
•  Hungary 
•  Lithuania 
•  Poland 
•  Spain 

•  Belgium (declaration for fitness for Group 1) 
•  Croatia (medical examination) 
•  Cyprus (renewed photo) 
•  Czech Rep. (no requirement)) 
•  Denmark (if expired over 3 years, re-test) 
•  Finland (if expired over 2 years, re-test for Group 1) 
•  Germany (no requirement) 
•  Ireland (self-declaration of fitness, verification of normal residence) 
•  Italy (psycho-physical examination) 
•  Latvia (medical examination) 
•  Luxembourg (medical check over 60 years) 
•  Netherlands (no requirement) 
•  Norway (renewed photo) 
•  Romania (physical check) 
•  Iceland (medical examination) 
•  Slovakia (psychological and health examination for category C1-DE) 
•  Slovenia (no requirements) 
•  Sweden (new photo)  

164 

 
 
 
Have the driving licence directives contributed to a decrease in the number of instances of fraud as compared to the instances of 
fraud as compared to the period prior to their first implementation (1983)? (N=32) 

Yes 

No 

Mixed opinions  

Do not know / cannot assess 

Table 4   

Forged 
detected per year 

driving 

licences 

fraud 
licence 
Driving 
involving citizens of other EU 
countries per year 

Belgium,  Czechia  ,  Cyprus, 
Denmark,  Finland,  Hungary, 
Latvia, 
Portugal, 
Poland, 
Slovakia, Slovenia 

Cyprus,  Czechia  ,  Hungary, 
Finland,  Portugal,  Poland, 
Latvia, 
Luxembourg, 
Slovakia, Slovenia 

Netherlands  

Bulgaria366, 
Luxembourg367 

Italy, Netherlands 

Bulgaria 

licence 

Driving 
involving  citizens  of 
countries per year 

fraud 
third 

Cyprus,  Czechia  ,  Denmark, 
Poland 

Belgium, 
Finland, 
Netherlands, Portugal 

Bulgaria, 
Luxembourg 

EU:  Austria,  Estonia,  Greece,  Croatia, 
Italy, 
France,  Germany, 
Lithuania, Romania, Spain, Sweden 
EEA: Iceland, Norway 

Ireland, 

EU: Austria, Belgium, Estonia, Greece, 
Croatia,  Denmark,  France,  Germany, 
Ireland,  Lithuania,  Romania,  Spain, 
Sweden 
EEA: Iceland, Norway 

EU:  Austria,  Estonia,  Greece,  Croatia, 
France,  Germany,  Ireland,  Hungary, 
Italy,  Latvia,  Lithuania,  Romania, 
Slovakia, Slovenia, Spain, Sweden 
EEA: Iceland, Norway 

Source: Survey with national authorities. 

366   Note that 2 national authorities from Bulgaria have responded to this question and their response was contradictory (one answered 'Yes' whereas the other answered 'No'). 

367   Note that 2 national authorities from Luxembourg have responded to this question and their response was contradictory (one answered 'Yes' whereas the other answered 'No'). 

165 

 
 
 
                                                           
To what extent do you agree with the following statements on current and future needs in terms of legal, social, and 
technological considerations and developments?  

Table 5 

166 

 
 
 
 
 
Judgments of the Court of Justice of the European Union in preliminary rulings on driving licences 

Table 6 

Case 
number 

Date 
judgment 

of 

MS 

Subject 

C-56/20 

29/04/2021  DE 

C-47/20 

29/04/2021  DE 

C-112/19 

28/10/2020  DE 

Request  for  a  preliminary  ruling  from 
Administrative Court of Baden-Württemberg, DE) in the proceedings AR v Stadt Pforzheim. 
Driving licences – Mutual recognition – Withdrawal of the licence in the territory of a Member State other 
than the issuing Member State  –  Affixing of an endorsement to  the driving licence indicating that  it is  not 
valid within that Member State 

the  Verwaltungsgerichtshof  Baden-Württemberg  (Higher 

Request for a preliminary ruling from the Bundesverwaltungsgericht (Federal Administrative Court, DE) in 
the proceedings F. v Stadt Karlsruhe 
Driving licences – Withdrawal of the licence in the territory of a Member State other than the issuing 
Member State – Renewal of the licence by the issuing Member State after the withdrawal decision – No 
automaticity of mutual recognition 

Request for a preliminary ruling from the Verwaltungsgericht Aachen (Administrative Court, Aachen, DE) in 
the proceedings Marvin M. v Kreis Heinsberg 
Directive 2006/126/EC – Article 2(1) and Article 11(4) – Driving licence – Mutual recognition – Extent of 
the obligation to recognise – Driving licence having been the subject of an exchange – Exchange made at a 
time when the right to drive had been withdrawn by the issuing Member State – Fraud – Refusal to recognise 
the driving licence issued in the context of the exchange 

C-9/18 

28/02/2019  DE 

Request  for  a preliminary  ruling  from  the Oberlandesgericht  Karlsruhe (Higher Regional Court,  Karlsruhe, 
DE) in the criminal proceedings against Detlev Meyn 

167 

 
 
 
C-195/16 

26/10/2017  DE 

C-632/15 

26/04/2017  RO 

C-664/13 

25/06/2015  LV 

C-339/14 

21/05/2015  DE 

Directive 2006/126/EC — Mutual recognition of driving licences — Refusal to recognise a driving licence 
issued in another Member State — Right to drive established on the basis of a driving licence 

Request  for  a  preliminary  ruling  from  the  Amtsgericht  Kehl  (Local  Court,  Kehl,  DE)  in  the  criminal 
proceedings against I. 
Directive 2006/126/EC  — Article 2(1)  — Mutual  recognition  of driving licences  — Definition of ‘driving 
licence’  —  Driving  licence  pass  certificate  authorising  its  holder  to  drive  in  the  Member  State  having 
awarded it before the issue of the definitive driving licence  — Situation in  which the holder of a  test pass 
certificate  drives  a  vehicle  in  another  Member  State  —  Obligation  to  recognise  the  test  pass  certificate  — 
Penalties imposed on the holder of the test pass certificate for driving a vehicle outside of the Member State 
in which it was awarded — Proportionality 

Request for a preliminary ruling from the Înalta Curte de Casație şi Justiție (High Court of Cassation and 
Justice, RO) in the proceedings Costin Popescu v Guvernul României and Others 
Directive 2006/126/EC — Article 13(2) — Concept of ‘entitlement to drive granted before 19 January 2013’ 
— National legislation transposing the directive — Obligation to obtain a driving licence imposed on persons 
who were allowed to ride a moped without a licence before the entry into force of that legislation 

Request for a preliminary ruling from the Administratīvā apgabaltiesa (Regional Administrative Court, LV) 
in  the  proceedings  VAS  „Ceļu  satiksmes  drošības  direkcija“  (Department  of  Road  Safety,  CSDD)  and 
Latvijas  Republikas  Satiksmes  ministrija  (Ministry  of  Transport  of  the  Republic  of  Latvia)  v  Kaspars 
Nīmanis. 
Driving licence  — Renewal  by the issuing Member State  — Condition of residence in  the territory of that 
Member State — Declaration of residence 

Request for a preliminary ruling from the Oberlandesgericht Nürnberg (Higher Regional Court, Nuremberg, 
DE) in the criminal proceedings against Andreas Wittmann. 
Directive  2006/126/EC  —  Mutual  recognition  of  driving  licences  —  Period  of  prohibition  —  Issue  of  the 
driving licence by a Member State before the entry into force of a period of prohibition in the Member State 
of  normal  residence  —  Grounds  for  refusing  to  recognise  in  the  Member  State  of  normal  residence  the 
validity of a driving licence issued by another Member State 

168 

 
C-260/13 

23/04/2015  DE 

C-356/12 

22/05/2014  DE 

C-467/10 

01/03/2012  DE 

C-419/10 

26/04/2012  DE 

C-224/10 

13/10/2011  DE 

Request  for  a  preliminary  ruling  from  the  Verwaltungsgericht  Sigmaringen  (Administrative  Court, 
Sigmaringen, DE) in the proceedings Sevda Aykul v Land Baden-Württemberg 
Directive 2006/126/EC — Mutual recognition of driving licences — Refusal of a Member State to recognise, 
in  the  case  of  a  person  having  driven  under  the  influence  of  narcotic  substances,  the  validity  of  a  driving 
licence issued by another Member State 

Request for a preliminary ruling from the Bayerischer Verwaltungsgerichtshof (Higher Administrative Court 
of Bavaria, DE) in the proceedings Wolfgang Glatzel v Freistaat Bayern 
Directive  2006/126/EC  —  Point  6.4  of  Annex  III  —  Validity  —  Charter  of  Fundamental  Rights  of  the 
European Union — Articles 20, 21(1) and 26 — United Nations Convention on the Rights of Persons with 
Disabilities  —  Driving  licences  —  Physical  and  mental  fitness  to  drive  a  motor  vehicle  —  Minimum 
standards — Visual acuity — Equal treatment — No possibility of derogation — Proportionality 

Reference for a preliminary ruling from the Landgericht Gießen (Regional Court, Gießen, DE) in the criminal 
proceedings against Baris Akyüz 
Directives 91/439/EEC and 2006/126/EC — Mutual recognition of driving licences — Refusal of a Member 
State  to  recognise,  in  respect  of  a  person  who  does  not  satisfy  the  physical  and  mental  requirements  for 
driving under the laws of that Member State, the validity of a driving licence issued by another Member State 

Reference  for  a  preliminary  ruling  from  the  Bayerischer  Verwaltungsgerichtshof  (Higher  Administrative 
Court of Bavaria, DE) in the proceedings Wolfgang Hofmann v Freistaat Bayern. 
Directive 2006/126/EC — Mutual recognition of driving licences — Refusal by a Member State to recognise, 
in favour of a person whose driving licence was withdrawn on its territory, the validity of a driving licence 
issued by another Member State 

Reference for a preliminary ruling from the Landgericht Baden-Baden (Regional Court, Baden-Baden, DE) 
in the criminal proceedings against Leo Apelt. 
Directive 91/439/EEC - Mutual recognition of driving licences - Withdrawal of the national driving licence 
issued by the Member State of residence and issue of a driving licence for vehicles in categories B and D by 
another Member State - Refusal of recognition by the Member State of residence - Obligation to hold a valid 
licence for vehicles in category B at the time of issue of the licence for vehicles in category D. 

169 

 
Annex 6: REFIT costs and benefits 

I. Overview of costs – benefits identified in the evaluation 

Citizens/Consumers  

Businesses 

Administrations 

Other 

Qualitative 

Quantitative / 
monetary 

Qualitative 

Quantitative / 
monetary  

Qualitative  Quantitative / 

Qualitative 

monetary  

Quantitative 
/ monetary 

Benefits 

Indirect social benefits 

Economic benefits of 
the introduction of a 
common Community 
Model driving licence 

Limited qualitative 
evidence of 
improvements in 
perceived  road 
safety  

Limited qualitative 
evidence of 
reduction  of cost 

No quantitative 
evidence 

No data available  No data available 

No quantitative 
evidence 

No evidence of positive economic 
impact on businesses.  

Economic benefits of 
the harmonised rules 
on administrative 
validity periods 

Limited qualitative 
evidence of 
reduction in costs 

No quantitative 
evidence 

No evidence of positive economic 
impact on businesses 

Weak qualitative proof of 
positive direct economic 
impact. 
Weak qualitative evidence of 
cost-savings for MS 
authorities  

No 
quantitative 
evidence 

Weak 
qualitative 
proof of 
positive direct 
economic 
impact 

No evidence 

No quantitative 
evidence 

No evidence of positive economic 
impact on businesses 

no data 
available 

No data 
available 

Economic benefits of 
rules on progressive 
access to category A 
driving licences 

Environmental 

No  evidence found  on environmental 

170 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
benefits 

benefits 

Unintended benefits 
(economic/social) 

No qualitative evidence of unintended 
indirect economic/social benefits for 
citizens. 

Indirect positive 
impact on economy 

No evidence found on expected indirect 
positive economy impact the directive led 
to optimised use of existing infrastructure. 

Indirect social benefits 
on safety 

No quantitative evidence of expected 
indirect positive social impact that 
directive led to improved safety. 

Indirect environmental 
benefit 

No evidence found on expected indirect 
positive environmental impact of the 
directive. 

Citizens/Consumers  

Businesses 

Administrations 

[Other…] 

Costs 

Qualitative 

Quantitative / 
monetary 

Qualitative 

No qualitative evidence 

Mixed finding as to 
marginal raises and 
decreases in costs 

Economic costs of the 
introduction of a 
common Community 
Model driving licence 

Significant variation 
in the cost of driving 
licence fees applied in 
Member States. 
Significant 
differences are found 
in the driving licence 
fees incurred in 
Member States. For a 
first-time application, 
they vary between 

171 

Quantitative 
/ monetary  

No 
quantitative 
evidence 

Qualitative 

Quantitative 
/ monetary  

Mixed 
finding as to 
marginal 
raises and 
decreases in 
costs 

Citizens/Co
nsumers  

Qualitative 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
EUR 175 and EUR 6 
(categories A, B) and 
between EUR 218 
and EUR 8 
(categories C and D). 
For exchange, the fees 
vary between EUR 
145 and EUR 7 
(categories A, B) and 
between EUR 208 
and EUR 7 
(categories C and D). 

Economic costs of the 
harmonised rules on 
administrative validity 
periods 

Economic costs of the 
rules on progressive 
access to category A 
driving licences 

Increased cost for 
citizens 

No quantitative 
evidence 

No qualitative evidence 

No qualitative evidence 

Increased cost for 
citizens 

No quantitative 
evidence of the 
increase in cost 
compared to baseline. 
However, one 
stakeholder estimates 
that the costs for 
obtaining an A 
licence in Europe can 
range between EUR 
800 to EUR 3,000. 

No raise 

No 
quantitative 
evidence 

No raise 

No 
quantitative 
evidence 

172