COMMISSION STAFF WORKING DOCUMENT IMPACT ASSESSMENT REPORT Accompanying the documents Proposal for a DIRECTIVE OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL on driving licences, amending Directive (EU) 2022/2561 of the European Parliament and of the Council, Regulation (EU) 2018/1724 of the European Parliament and of the Council and repealing Directive 2006/126/EC of the European Parliament and of the Council and Commission Regulation (EU) No 383/2012 and Proposal for a DIRECTIVE OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL on the Union-wide effect of certain driving disqualifications
Date: 2023-03-01
Institutions: Directorate-General for Mobility and Transport, European Commission
Subjects: EU Member State, EU national, administrative cooperation, driving licence, free movement of persons, health control, penalty, road safety, traffic offence, transport accident

EN 

  EN 

   EUROPEAN COMMISSION  Brussels, 1.3.2023  SWD(2023) 128 final  COMMISSION STAFF WORKING DOCUMENT  IMPACT ASSESSMENT REPORT  Accompanying the documents Proposal for a DIRECTIVE OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL on driving licences, amending Directive (EU) 2022/2561 of the European Parliament and of the Council, Regulation (EU) 2018/1724 of the European Parliament and of the Council and repealing Directive 2006/126/EC of the European Parliament and of the Council and Commission Regulation (EU) No 383/2012         and        Proposal for a DIRECTIVE OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL           on the Union-wide effect of certain driving disqualifications       {COM(2023) 127 final} - {SEC(2023) 350 final} - {SWD(2023) 129 final}  
 
 
Table of contents 

1 

INTRODUCTION: POLITICAL AND LEGAL CONTEXT ...........................................................................1 

1.1 
1.2 
1.3 

1.4 
1.5 
1.6 

Political context .................................................................................................................................................1 
Legal context .....................................................................................................................................................2 
Synergies with the Directive facilitating cross-border exchange of information on road-safety-related 
traffic offences ..................................................................................................................................................4 
Synergies with other EU policy instruments .....................................................................................................6 
Evaluation of the Driving Licence Directive .....................................................................................................7 
Sustainable Development Goals ........................................................................................................................7 

2 

PROBLEM DEFINITION .................................................................................................................................7 

2.1  What are the problems? .....................................................................................................................................7 
2.1.1  Problem 1: High number of unfit drivers on EU roads ........................................................................8 

2.1.2  Problem  2:  Barriers  to  the  free  movement  of  people  due  to  inadequate  or  unnecessary 

procedures for driving licences .......................................................................................................... 10 

2.2  What are the problem drivers? ........................................................................................................................ 12 
2.2.1  Problem  driver  1:  Drivers  with  insufficient  skills,  knowledge,  experience  and/or  risk 

awareness are present on EU roads .................................................................................................... 12 
2.2.2  Problem driver 2: Drivers with dangerous behaviour are present on EU roads ................................. 13 

2.2.3  Problem driver 3: Drivers that are not physically or mentally fit to drive are present on EU 

roads .................................................................................................................................................. 15 

2.2.4  Problem driver 4: Applicants face difficulties to obtain a driving licence due to inadequate 

or unnecessary procedures ................................................................................................................. 16 

2.2.5  Problem driver 5: Holders of licences face difficulties to have their driving rights maintained 

or recognised in cross-border context due to inadequate or unnecessary procedures ........................ 18 

2.3 

How likely is the problem to persist? .............................................................................................................. 20 
2.3.1  Problem 1: High number of unfit drivers on EU roads. ..................................................................... 20 

2.3.2  Problem  2:  Barriers  to  the  free  movement  of  people  due  to  inadequate  or  unnecessary 

procedures for driving licences. ......................................................................................................... 21 
2.3.3  Foresight ............................................................................................................................................ 22 

3 

WHY SHOULD THE EU ACT? ..................................................................................................................... 22 

3.1 
3.2 
3.3 

4.1 
4.2 

4 

5 

Legal basis ....................................................................................................................................................... 22 
Subsidiarity: Necessity of EU action ............................................................................................................... 23 
Subsidiarity: Added value of EU action .......................................................................................................... 23 

OBJECTIVES: WHAT IS TO BE ACHIEVED? ............................................................................................ 24 

General objectives ........................................................................................................................................... 24 
Specific objectives........................................................................................................................................... 24 

WHAT ARE THE AVAILABLE POLICY OPTIONS? ................................................................................. 26 

5.1  What is the baseline from which options are assessed? .................................................................................. 26 
Description of the policy options .................................................................................................................... 27 
5.2 
5.2.1  Discarded policy measures ................................................................................................................ 27 

5.2.2  Retained policy measures .................................................................................................................. 28 
5.2.3  Description of the options .................................................................................................................. 29 

5.2.4  Main trade-offs .................................................................................................................................. 33 

6 

WHAT IS THE IMPACT OF THE POLICY OPTIONS? .............................................................................. 34 

6.1 

Economic impact ............................................................................................................................................. 35 

II 

 
6.1.1  Impact on public administrations ....................................................................................................... 35 
6.1.2  Impact on the private sector ............................................................................................................... 38 

6.1.3  Impact on citizens .............................................................................................................................. 39 
6.1.4  Impact on SMEs ................................................................................................................................ 44 

6.1.5  Digital by default ............................................................................................................................... 45 
6.1.6  Impact on the functioning of the internal market and on competition ............................................... 45 

6.2 

Social impact ................................................................................................................................................... 46 
6.2.1  Impacts on road safety ....................................................................................................................... 46 
6.2.2  Impact on fundamental rights ............................................................................................................ 48 

6.2.3  Impact on fraud .................................................................................................................................. 49 

6.3 

Environmental impact ..................................................................................................................................... 50 

7 

HOW DO THE OPTIONS COMPARE? ......................................................................................................... 51 

7.1 
7.2 
7.3 
7.4 

8.1 
8.2 
8.3 

8 

Effectiveness ................................................................................................................................................... 51 
Efficiency ........................................................................................................................................................ 52 
Coherence ........................................................................................................................................................ 53 
Subsidiarity and proportionality ...................................................................................................................... 54 

PREFERRED OPTION ................................................................................................................................... 58 

Identification of the preferred policy option and stakeholder views ............................................................... 58 
REFIT (simplification and improved efficiency) ............................................................................................ 61 
Application of the ‘one in, one out’ approach ................................................................................................. 62 

9 

HOW WILL ACTUAL IMPACT BE MONITORED AND EVALUATED? ................................................ 62 

ANNEX 1: PROCEDURAL INFORMATION ................................................................................................................ 64 

ANNEX 2: STAKEHOLDER CONSULTATION (SYNOPSIS REPORT) .................................................................... 66 

ANNEX 3: WHO IS AFFECTED AND HOW? .............................................................................................................. 87 

ANNEX 4: ANALYTICAL METHODS ......................................................................................................................... 94 

ANNEX 5: DISCARDED POLICY MEASURES ......................................................................................................... 134 

ANNEX 6: RETAINED POLICY MEASURES ............................................................................................................ 139 

ANNEX 7: VEHICLE CATEGORIES .......................................................................................................................... 144 

ANNEX 8: MINIMUM AGES ....................................................................................................................................... 146 

ANNEX  9:  LINKS  BETWEEN  MAIN  CONCLUSIONS  OF  THE  EX-POST  EVALUATION  AND  THE 

IMPACT ASSESSMENT .......................................................................................................................... 148 

ANNEX 10: EFFECTS ON ROAD SAFETY – QUALITATIVE ASSESSMENT ....................................................... 149 

ANNEX 11: EFFECTIVENESS OF THE POLICY OPTIONS ..................................................................................... 152 

III 

 
 
 
 
Glossary 

Term or acronym  Meaning or definition 

ACEM 

ADAS 

API 

BAC 

BOE 

European Association of Motorcycle Manufacturers 

Advanced Driver Assistance Systems 

Application Programming Interface 

Blood Alcohol Content  

Barrel of Oil Equivalent 

CADAS 

Centralised Automated Driving Assistance System 

CARE 

CBE  

Community database on road accidents 

Cross Border Enforcement 

CEETTAR 

Confédération Européenne des Entrepreneurs de Travaux Techniques 
Agricoles Ruraux et Forestiers 

CNG 

Compressed Natural Gas 

COPERT 

COmputer Programme to calculate Emissions from Road Transport 

CPC 

DDL 

DKU 

DUI 

ECF 

ECLI 

EFTA 

EIDAS 

ETF 

ETSC 

Certificate of Professional Competence 

Data Definition Language 

Dansk Kørelærer-Union 

Driving Under the Influence (of alcohol/drugs…) 

European Cyclists’ Federation 

European Case Law Identifier 

European Free Trade Association 

Electronic Identification, Authentication and trust Services 

European Transport Workers Federation 

European Transport Safety Council 

EUCARIS 

European Car And Driving licences Information System 

FEVR 

FIA 

GDP 

Fédération Européenne des Victimes de la Route 

Fédération Internationale de l’Automobile 

Gross Domestic Product 

IV 

 
Term or acronym  Meaning or definition 

GDPR 

General Data Protection Regulation (EU) 2016/679 

GDV 

GP 

HGV 

HPT 

IEC 

IIA 

IRU 

ISCO 

ISO 

LCV 

LNG 

LPG 

MS 

German Insurance Association 

General Practitioner 

Heavy Goods Vehicle 

Hazard Perception Test 

International Electrotechnical Commission 

Inception Impact Assessment 

International Road Transport Union 

International Standard Classification of Occupations 

International Standardisation Organisation 

Light Commercial Vehicle 

Liquefied Natural Gas 

Liquefied Petroleum Gas 

Member State(s) 

OECD 

Organisation for Economic Co-operation and Development 

OPC 

PIN 

Open Public Consultation 

Road Safety Performance Index 

QR code 

Quick Response code 

RESPER 

Réseau des Permis (EU driving licence network) 

SDG 

SME 

SSMS 

TFEU 

UITP 

Sustainable Development Goal 

Small and Medium-sized Enterprises 

Sustainable and Smart Mobility Strategy 

Treaty on the Functioning of the European Union 

Union Internationale des Transports Publics 

UNECE 

United Nations Economic Commission for Europe 

VTI 

Swedish National Road and Transport Research Institute 

V 

 
1 

1  INTRODUCTION: POLITICAL AND LEGAL CONTEXT 

1.1  1.1 

Political context 

This Impact Assessment accompanies a legislative proposal for the revision of Directive 2006/126/EC on 
driving  licences  (hereinafter  “the  DL  Directive”  or  “the  Directive”)1  and  a  legislative  proposal  for  a 
Directive  on  the  Union  wide  effect  of  certain  driving  disqualifications,  which  was  planned  as  an 
integral part of the DL Directive but due to legal considerations has been separated and is presented 
as an integral, separate legislative proposal for a new directive. 

One of the most advanced frameworks in the world on driving licences is in force and applied by the EU 
and other EEA Member States. Altogether it covers more than 250 million drivers. The cornerstone of this 
structure is the DL Directive which establishes a common legal framework of measures for the recognition 
and issuance of driving licences in the European Union. Its objectives are the improvement of road safety 
and facilitating the free movement of citizens within the EU. With freedom of movement established by the 
European Single Market, EU rules on driving licences have contributed to ease cross-border travels and 
facilitated change of residence for citizens establishing themselves in another Member State. Nonetheless, 
citizens are still confronted with inconsistencies between national approaches, which in turn affect their 
driving rights. They also face shortcomings and difficulties in the implementation of the Directive.   

Road safety in the EU has improved quite significantly over the last 20 years. The number of road fatalities 
has gone down by 61.5% from around 51,400 in 2001 to around 19,800 in 2021. However, the 2011 White 
Paper’s target2 to halve road casualties by 2020 compared to 2010 was missed and the decade only recorded 
a reduction of 37%3, despite the unprecedented drop in road traffic volumes in the wake of the COVID-19 
pandemic which has heavily influenced the decrease of road fatalities between 2019 and 20204. However, 
the improvement in road safety has not been as strong as needed. The slowdown in the reduction of the 
number of road deaths that set in around 2014 (see Figure 1) prompted the transport ministers of the EU to 
issue a ministerial declaration on road safety at the informal transport Council in Valletta in March 20175. 
In that declaration, the Member States called upon the Commission to explore the strengthening of the EU’s 
road safety legal framework to ensure that even less people die in road crashes.  

As part of its third Mobility Package of May 2018, the Commission issued “A Strategic Action Plan on 
Road Safety”6 where it called for a new approach to counter the stagnating trend in road safety figures in 
the EU and move closer to the long-term goal of zero road fatalities across the EU by 2050 (“Vision Zero”).  

In June 2019, the Commission published the EU Road Safety Policy Framework 2021-2030 – Next steps 
towards “Vision Zero”7. In it, the Commission proposed new interim targets of reducing the number of road 
deaths by 50% between 2020 and 2030 as well as reducing the number of serious injuries by 50% in the 
same period, as recommended by the Valletta Declaration, and decided to implement the so-called “Safe 
System approach”. This approach considers death and serious injury in road collisions largely preventable, 
while acknowledging that collisions will continue to occur. It takes as a point of departure the fact that 
people make mistakes and aims to ensure that such mistakes do not give rise to fatalities or serious injuries 

1   Directive 2006/126/EC of the European Parliament and of the Council of 20 December 2006 on driving licences (Recast) (Text 

with EEA relevance), OJ L 403, 30.12.2006, p. 18–60 

2   European Commission, Roadmap to a Single European Transport Area – Towards a competitive and resource (2011), White Paper 
3   From 29 600 causalities in 2010 to 18 800 in 2020 
4   During the first lockdown, ETSC reported a 70-85% reduction in traffic volumes in major European cities (ETSC) 
5   See:  https://eumos.eu/wp-content/uploads/2017/07/Valletta_Declaration_on_Improving_Road_Safety.pdf;  in  June  2017,  the 

Council adopted conclusions on road safety endorsing the Valletta Declaration (see document 9994/17). 

6   Annex I to COM(2018) 293 final (Europe on the Move. Sustainable mobility for Europe: safe, connected and clean) 
7   SWD(2019) 283 final 

1 

 
                                                 
by holistically focusing on five pillars: safe roads and roadsides, safe speeds, safe road users, safe vehicles, 
and fast and effective post-crash care, which all contribute to reducing the impact of crashes.  

Figure 1: Road fatalities in the current EU27 between 2000 and 2021, with EU target for 20308 

In  its  Sustainable  and  Smart  Mobility  Strategy9  of  2020,  the  Commission  reiterated  the  target  of  zero 
fatalities in all modes of transport by 2050 and announced the revision of the DL Directive, to address 
technological innovation including mobile driving licences, under Flagship 10 “Enhancing transport safety 
and security”. In October 2021, the European Parliament adopted a resolution on the EU Road Safety Policy 
Framework 2021-203010, calling on the Commission to further promote road safety, notably through higher 
standards in terms of driver training.  

The UN Global Plan for the Decade of Action11 released in October 2021, which also emphasised the “Safe 
System  approach”,  promotes  the  same  reduction  targets  already  in  place  at  EU  level.  It  calls  also  on 
continued improvements, including on enhancement of laws and their enforcement with a special attention 
to vulnerable road users and young people. 

Finally, it can be also underlined that the commercial road transport sector faces increasing demand and a 
significant shortage of drivers (400 000 for freight and more than 17 000 for passengers).12 While many 
actions are required to allow the sector to answer to the need, the driving licence plays naturally an important 
role for the access to the profession of driver.  

1.2  1.2 

Legal context 

The EU rules on driving licences aim to ensure a high level of road safety across the European Union by 
establishing  common  standards  on  skills,  knowledge,  physical  and  mental  fitness  of  drivers  and  the 
verification  thereof.  They  also  facilitate  the  free  movement  of  persons,  by  reducing  the  administrative 
burden on persons transferring their residence to a Member State other than the one that issued their driving 
licence. Finally, they include measures supporting the fight against fraud and forgery.  

The first Directive on driving licences (Directive 80/1263/EEC)13 introduced the very first set of rules in 
the  EU  as  regards  harmonisation  of  the  national  driving  licence  schemes,  in  particular  through  the 

8   Source: https://transport.ec.europa.eu/2021-road-safety-statistics-what-behind-figures_en  
9    COM(2020) 789 final 
10   P9_TA(2021)0407 https://www.europarl.europa.eu/doceo/document/TA-9-2021-0407_EN.pdf  
11   Decade of Action - United Nations Sustainable Development 
12   IRU driver shortage report 2022 
13   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 

 
 
 
                                                 
introduction of a Community model of the licence, through the preliminary definition of vehicle categories 
and by laying down the conditions under which driving licences can be issued or exchanged across the EU. 
These  rules  were  further  refined  and  extended  in  the  second  driving  licences  Directive  (Directive 
91/439/EEC)14. Most importantly, the mutual recognition of driving licences issued by Member States was 
established and requirements for a minimum age to obtain a driving licence were introduced. The currently 
applicable rules were established by the DL Directive adopted in 2006 and became applicable as of 19 
January 2009.  

Since its adoption in 2006, the Directive has been amended eleven times between 2009 and 2020, mainly 
to improve the harmonisation of common standards and requirements, as well as to adapt to technological 
developments.  

The Driving Licence Directive specifies the model of the Union driving licence (physical card). It 
defines the categories of vehicles which can be driven with a given driving licence and the minimum 
age for obtaining it15. It also provides Member States with the optional flexibility to extend certain 
driving rights to additional vehicles under certain conditions with an effect limited to their territories.  

The  Directive  also  defines  the  conditions  for  the  issuance  and  renewal  of  driving  licences,  in 
particular: 

  the normal residence of the person concerned, enabling the identification of the Member State that should 

issue the driving licence.  

The implementation of this concept differs across the EU. In particular, it depends on whether a Member 
State holds or not a registry for foreigners who are EU nationals; 

  the requirements on driving skills and knowledge to be met at the theoretical and practical tests.  

The Directive does not lay down rules on the training to be followed before the tests. They are therefore 
regulated at national level; 

  the requirements on physical and mental fitness to drive for applicants and drivers  

The  methods  to  assess  the  compliance  with  these  requirements  are  not  specified  in  detail,  which 
results in differences among Member States. In addition, the verification is optional at the renewal of 
driving licences for the categories A (motorcycle) and B (car and small vans). Member States may 
also decide for more frequent checks when the holder is aged of 55 years or more. These requirements 
are minimum conditions to be met and Member States can decide to adopt stricter rules to increase 
road safety. 

The Directive introduces the EU network for the exchange of information related to driving licences 
between  national  authorities  (RESPER).  It  allows  to  verify  driving  rights  based  on  the  issuance 
number  of  a  driving  licence  and  to  verify  if  an  applicant  has  already  a  driving  licence  issued  by 
another Member State. It also provides for the possibility of secure messages for any other matter. 
Such network is used for the implementation of the Directive on driving licences. Some Member 
States are accessing RESPER through the EUCARIS network16.  

14   Council Directive of 29 July 1991 on driving licences (91/439/EEC), OJ L 237, 24.8.1991, p. 1. 
15   The description of the vehicle categories is provided in Annex 7 of this Impact Assessment and a synthesis of the minimum ages 

can be found in Annex 8 thereof. 

16   EUCARIS – EUCARIS is the EUropean CAR and driving license Information System. 

3 

 
                                                 
Based on an amendment of the Directive adopted in 2018, RESPER can also be used for the purpose 
of control, solely in relation to implementing the Directives on driving licences, on the qualification 
of professional drivers and on the cross border enforcement of road-traffic offenses. 

The Directive provides also for specific rules applicable to various aspects of exchange, replacement 
and withdrawal of driving licences.  

It should also be noted that the Directive does not cover all matters regarding driving licences (for 
example, the EU rules related to licences issued by a third country are very limited in scope) and 
provides some flexibility regarding its implementation (for example the minimum age for a driving 
licence of category AM – mopeds – is set to 16 but can vary from 14 to 18 years across the EU). 

Regarding driving licences issued by third countries, the Directive specifies the information to be 
reported on the EU driving licence in the context of an exchange and restricts the recognition of the 
driving licence in case the holder changes his/her normal residence in the future. The Directive also 
establishes  certain  effects  of  a  withdrawal  in  case  the  holder  relocates  in  another  Member  State. 
However, international agreements and national laws provide for the main rules on these situations.  

Indeed, rules on foreign driving licences are largely laid down in the 1968 Vienna Convention17 in 
most  Member  States.  However,  in  Spain,  Cyprus,  Malta,  and  Ireland,  its  predecessor,  the  1949 
Geneva Convention18 still applies, which Germany and Latvia are not Contracting Parties of. Both 
the Geneva Convention and the Vienna Convention provide rules to ensure that duly issued domestic 
or international  driving licences from one Contracting Party are recognised in  another one, under 
certain conditions19. Contrary to the rules laid down in the Directive, the Conventions only establish 
the right to drive when in transit and do not allow for the seamless exchange of the driving licences 
between the Contracting Parties in case drivers change their residence. The national laws identify the 
foreign  driving  licences  that  can  be  exchanged  (which  issuing  country,  which  category)  and  the 
conditions associated to the exchange (for example, to undergo a medical examination).  

Finally,  road  traffic  rules  are  a  national  prerogative,  especially  for  what  concerns  thresholds  and 
consequences of offenses such as financial penalties, penalty points or driving disqualification. In 
most  of  the  cases,  the  effects  of  a  driving  ban  affecting  a  non-resident  are  usually  limited  to  the 
territory of the state where the offense has been committed.  

1.3  1.3 

Synergies with the Directive facilitating cross-border exchange of information on 

road-safety-related traffic offences 

Directive  (EU)  2015/413  (called  hereafter  the  CBE  Directive)  aims  to  improve  road  safety  by 
ensuring equal treatment of resident and non-resident offenders. In the event of certain road-safety-
related traffic offences having been committed with a vehicle registered in another Member State, it 
grants the Member State where the offence occurred access to the vehicle registration data (VRD) of 
the Member State of registration of the vehicle concerned. This should facilitate the identification of 
a driver suspected of committing a road-safety-related traffic offence in a Member States other than 
that where the vehicle is registered, which is an important element in the cross-border enforcement 
of  traffic  offences.  An  effective  cross-border  enforcement  reduces  impunity  and  hence  induces  a 
more cautious behaviour by the drivers concerned. A more cautious behaviour should lead to fewer 
road accidents and hence a reduction in fatalities, injuries and material damage. However, the CBE 

17   Convention on Road Traffic done at Vienna in 1968 
18   Convention on Road Traffic done at Geneva in 1949 
19   More information on which convention applies in case the country of the driver and the one which roads are used are Contracting 

Parties to different (or neither) ones: Road Traffic Brochure_EN.pdf (unece.org)  

4 

 
                                                 
Directive does not provide for instruments enabling the mutual recognition of financial penalties or 
driving disqualifications.  

In its Article 15 on mutual assistance, the Driving Licence Directive provides also for a network for 
the  exchange  of  information  related  to  driving  licences  (RESPER).  It  can  be  used  for  the 
implementation of, and to control the compliance with the Driving Licence Directive, the Directive 
on  professional  qualifications20  and  Directive  (EU)  2015/413  21  (the  “CBE  Directive”).  There  is 
currently no legal certainty on the question whether RESPER can be used for the purposes of the 
CBE Directive (relying on EUCARIS) because of the formulation of Article 15 of the DL Directive 
and because of the fact that Article 4(4) of the CBE Directive stipulates that Member States must 
ensure that the exchange of information under the CBE Directive is carried out “without exchange of 
data involving other databases which are not used for the purposes of this Directive”. Consequently, 
a vast majority of law enforcement authorities are not using RESPER for the purpose of control.  

The CBE Directive is being revised in parallel to the revision of the Driving Licence Directive, for both 
legal reasons and reasons of consistency. In this context, the removal of restrictions on the use of other 
databases is considered. Access to RESPER for the purpose of enforcement will be possible under the 
conditions specified by the Driving Licence Directive and as a result, more offences are expected to be 
successfully investigated. This has been assessed in the context of the impact assessment accompanying the 
revision of the CBE Directive. In addition, the revision of the DL Directive will provide for clarification of 
all the use cases which require access to RESPER in the context of law enforcement, in order to completely 
remove legal uncertainties. The scope of the CBE Directive does not include driving disqualifications. The 
procedural steps included therein only cover measures that can facilitate the identification of the offender 
and measures related to the content of information that the identified person (mostly the owner or holder of 
the vehicle) must receive and the language of this information. The revision of the CBE Directive aims to 
improve enforcement through measures related to the investigation and better identification of offenders. It 
also aims to improve the protection of the fundamental and procedural rights of the offender. However, it 
will not provide the necessary legal basis for the mutual recognition of driving disqualifications. As the CBE 
Directive does not regulate the procedure to the point where a legally binding decision is made, or any issues 
relating to such a decision or the sanction contained in it, it is not a sufficient tool for mutual recognition 
(i.e. there is no decision to recognize). 

The  Court’s  recent  judgement  in  Case  C-266/21  (HV)  underlines  that  the  DL  Directive  not  only 
regulates situations in which a Member State suspends, pursuant to its national legislation and on 
account of unlawful conduct in its territory, the right to drive of the holder of a driving licence issued 
by another Member State insofar as it establishes that the effect of such suspension is limited to that 
territory  alone,  but  that  it  is  also  the  only  legislation  in  force  to  do  so.  Consequently,  the  mutual 
recognition of driving disqualification will be addressed in the context of this initiative. The revision 
of the DL Directive will also build on the corresponding CBE procedures to identify and bring the 
potential offender to justice in cases where the sanction is driving disqualification, like it is possible 
today for the case of financial penalties. In fact, the most crucial elements of this cooperation are 
already in place as the CBE Directive includes already the type of offences, which can be mutually 
recognised  in  order  to  give  rise  to  an  EU-wide  driving  disqualification,  such  as  excessive  speed 
driving and driving under the influence of alcohol. 

20   Directive (EU) 2022/2561 of the European Parliament and of the Council of 14 December 2022 on the initial qualification and 
periodic training of drivers of certain road vehicles for the carriage of goods or passengers (codification), OJ L 330, 23.12.2022, 
p. 46. 

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

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

5 

 
                                                 
On  the  other  hand,  by  using  the  procedures  within  the  CBE  Directive  not  only  the  effective 
investigation  of  these  offences  can  be  guaranteed  but  the  protection  of  the  fundamental  and 
procedural rights of the offenders as well. In that context it is important to note that the information 
letter contained within the current CBE Directive will be revised. The template provided in Annex II 
to the CBE Directive will be removed and a mandatory minimum content will be identified. This 
content will include an obligation to provide the offender with information on the possible sanctions 
for  the  offence  (explicitly  naming  driving  disqualification  as  an  example)  and  the  available  legal 
recourses. Certain parts of the information letter are planned to be given as information, even where 
the offender is not remotely detected but caught on the spot by authorities. This is important as this 
measure  would  ensure  that  the  offender  is  sufficiently  informed  about  his/her  available  legal 
possibilities  in  case  a  driving  disqualification  (or  other  sanction)  would  be  imposed  on  him/her. 
Should  the  Member  State  of  the  offence  not  comply  with  the  procedures  of  the  CBE  Directive, 
opportunities will be provided to the Member State that issued the driving licence to either refuse the 
recognition  of  the  decision  or  to  provide  additional  legal  recourse  before  enforcing  the  driving 
disqualification. 

1.4  1.4 

Synergies with other EU policy instruments 

The DL Directive governs driving rights according to vehicle categories. Certain categories are defined by 
reference to EU rules: 

 

 

Council  Directive  96/53/EC  laying  down  the  maximum  authorised  dimensions  in  national  and 
international  traffic  and  the  maximum  authorised  weights  in  international  traffic22,  allowing  to 
identify the types of alternatively fuelled vehicles; 

Regulation  (EU)  No  168/2013  on  the  approval  and  market  surveillance  of  two-  or  three-wheel 
vehicles and quadricycles23, allowing to identify the types of mopeds, motorcycles, motor tricycles 
and quadricycles. 

The  DL  Directive  determines  the  minimum  ages  to  obtain  a  driving  licence  for  (future)  professional 
drivers, which are also subject to Directive (EU) 2022/2561 on the initial qualification and periodic training 
of drivers of certain road vehicles for the carriage of goods or passengers24.  

In addition, rules on the protection of personal data also apply to the exchange of information related 
to driving licences, in particular: 

 

 

Regulation (EU) 2018/1725 on the protection of natural persons with regard to the processing of 
personal  data  by  the  European  Union  institutions,  bodies,  offices  and  agencies  and  on  the  free 
movement of such data25;  

Regulation  (EU)  2016/679  on  the  protection  of  natural  persons  with  regard  to  the  processing  of 
personal data and on the free movement of such data (General Data Protection Regulation)26. 

Finally, the Commission has adopted on 3 June 2021 a proposal27 for the revision of Regulation (EU) 
No 910/2014 as regards establishing a framework for a European Digital Identity. This new framework 

22   https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:01996L0053-20190814 OJ L 235, 17.9.1996, p. 59–75 
23   OJ L 60, 2.3.2013, p. 52–128 
24   https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX%3A32022L2561 OJ L 330, 23.12.2022, p. 46–69 
25   https://eur-lex.europa.eu/legal-content/en/TXT/?uri=CELEX:32018R1725 OJ L 295, 21.11.2018, p. 39–98 
26   https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:02016R0679-20160504 OJ L 119, 4.5.2016, p. 1–88 
27   https://eur-lex.europa.eu/legal-content/EN/ALL/?uri=COM%3A2021%3A281%3AFIN COM(2021) 281 final 

6 

 
                                                 
provides building blocks relevant for the mobile driving licences. In particular, the electronic identity and, 
potentially, the electronic wallet features can be used to develop an interoperable solution for EU mobile 
driving licences.  

1.5  1.5 

Evaluation of the Driving Licence Directive 

An  ex-post  evaluation  of  the  DL  Directive  has  been  published  in  202228.  Despite  the  limitations 
regarding data availability, resulting in limited robustness of certain conclusions, the Directive was 
considered to have had a generally positive effect on improving road safety and has likely helped to 
facilitate the  free  movement of  citizens inside the EU. The evaluation acknowledged that the EU 
transport system is changing fast, due to the impact of digitalisation, an increasing emphasis on active 
modes  in  urban  transport,  the  emergence  of  new  forms  of  mobility,  developments  regarding 
connectivity, automation and the increasing role  of artificial intelligence, as well as the uptake of 
low- and zero-emission vehicles. This requires the DL Directive to be adapted, to address not only 
current needs but also future challenges. The main conclusions of the evaluation and how they have 
been considered in this impact assessment can be found in Annex 9. 

1.6  1.6 

Sustainable Development Goals 

The initiative aims at improving road safety. In the context of the United Nation’s 2030 agenda for 
sustainable development, it hence directly contributes to sustainable development goal #11 “Make 
cities and human settlements inclusive, safe, resilient and sustainable” and in particular to target 11.2 
“By 2030, provide access to safe, affordable, accessible and sustainable transport systems for all, 
improving road safety, notably by expanding public transport, with special attention to the needs of 
those in vulnerable situations, women, children, persons with disabilities and older persons”.  

2 

2  PROBLEM DEFINITION 

2.1  2.1 

What are the problems? 

The ex-post evaluation found that the Directive has contributed to an improvement of road safety. 
However, in light of the ambitious EU targets (Vision Zero and Valletta Declaration), more efforts 
are needed to reduce road fatalities and serious injuries. The revision of the Directive could contribute 
to it. Similarly, the Directive has had a positive impact on the free movement of citizens in the EU. 
However, certain provisions still result in administrative burden or obstacles to the free movement of 
people. This is the case of, for example, rules on normal residence and on the recognition of driving 
licences  issued  in  third  countries.  An  overview  of  the  problem  drivers,  problems  and  their 
implications is presented in Figure 2Figure 2. 

Figure 2: Problem tree 

28   Evaluation of the Directive 2006/126/EC of the European Parliament and of the Council of 20 December 2006 on driving licences 

_ SWD/2022/0017 final.  

7 

 
 
                                                 
2.1.1  Problem 1: High number of unfit drivers on EU roads 

Problem 1 is related to holders of driving licences whose presence on EU roads presents risks due to 
their  lack  of  fitness  to  drive.  In  many  serious  crashes  resulting  in  death,  serious  health  loss  and 
non-fatal injuries, the driver’s skills, knowledge, behaviour and medical fitness play an important 
role.  

Monitoring of road traffic fatalities and serious injuries does not account for the cause of an accident 
because it is often difficult to determine it accurately, being related to multiple factors (e.g. a small 
hole in the asphalt, a moment of distraction and insufficient fitness to react) and it is not determined 
at the time of data collection. It is therefore impossible to quantify accurately the underlying cause(s) 
of fatalities or serious injuries resulting from road accidents. In addition, and despite the fact that the 
ambitious EU targets on road safety are not met, road safety in the EU is quite advanced, with only 
42 road fatalities per million inhabitants in the EU, while the global average is 16729.  

Skills, knowledge, risk awareness and experience remain limited particularly for novice drivers. This 
constitutes  an intrinsic part of  the learning curve, but also the  reason for the  existence of driving 
licences, which establishes at what point of the learning curve (i.e.  the minimum requirements in 
terms of knowledge and experience) novice drivers are issued a licence and are allowed to drive on 
EU roads. The higher level of accidents and fatalities of novice drivers indicates that the requirements 
for issuing driving licences are not fully calibrated to road safety objectives. In 2019, young road user 
deaths represented around 23% of all road deaths in the EU and 2 out of 5 fatal collisions involved a 
young  driver  or  rider  (aged  15  to  30).30  According  to  the  CARE  database,  for  every  100,000 
experienced drivers31, on average there are 3 experienced driver fatalities per year, while for every 
100,000 novice drivers32, there are 10 novice driver fatalities.  

In  addition,  the  progressive  introduction  of  new  technologies  such  as  advanced  driver  assistance 
systems and, in the future, automated vehicles will have a substantial impact on the use of vehicles. 

29   https://www.acea.auto/figure/road-fatalities-per-million-inhabitants-europe-and-world/  
30   Source: ETSC PIN Flash Report 41 - https://etsc.eu/wp-content/uploads/PIN-Flash-41_web_FINAL.pdf 
31   More than11 years after obtaining their driving licence 
32   Less than 4 years after obtaining their driving licence 

8 

PROBLEM DRIVERSPROBLEMSEFFECTSDrivers withinsufficientskills, knowledge, experienceand/or riskawarenessare presenton Union roadsDrivers withdangerousbehaviorare presenton Union roadsDrivers thatare not physicallyor mentallyfit to drive are presenton Union roadsApplicantsface difficultiesto obtaina drivinglicence due to inadequateor unecessaryproceduresHoldersof licences face difficultiesto have theirdrivingrightsmaintainedor recognisedin cross border contextdue to inadequateor unecessaryproceduresProblem#1 : High numberof unfitdrivers on Union roadsProblem#2 : Barriersto the free movementof people due to inadequateor unecessaryproceduresfor drivinglicences Insufficientreductionof road trafficaccidents withfatalitiesand seriousinjuriesInabilityof somedrivers and applicantsto obtain, maintainor have recogniseddrivingrightsPD1PD2PD3PD4PD5 
 
 
                                                 
Whereas such technologies have the potential to improve road safety and contribute to more inclusive 
mobility, they  also  bring new  challenges  for the  drivers in  terms of skills  and knowledge of new 
functionalities, which are not covered by the current Directive.  

Another group of drivers unfit to drive are those with dangerous behaviour. From an EU perspective, 
it  concerns  more  specifically  drivers  committing  a  very  serious  infraction.  There  is  currently  no 
mutual recognition of driving disqualifications for offences committed in a Member State other than 
the one that issued the driving licence. When the disqualification concerns a non-resident, nothing 
prevents the latter from continuing to drive in all Member States, except for the one where he or she 
was convicted. As drivers who commit serious traffic offences in other Member States are not held 
accountable,  there  is  no  equal  treatment  of  resident  and  non-resident  offenders  in  the  EU.  This 
situation creates imunity and is not conducive to improving road safety.  

Finally, the last category of drivers presenting risk on European roads are those that are not physically 
or mentally fit to drive. The ex-post evaluation has found that the current age-based screening is no 
longer  perceived  as  the  most  relevant.  Although  there  is  evidence  about  potential  physical 
deterioration connected with age, some studies have concluded that specific medical conditions, such 
as substance abuse, mental disorders, epilepsy and diabetes, heart conditions and sleep apnoea are 
not  necessarily  connected with  age, while at  the  same time being  more important  factors when it 
comes to the medical fitness to drive.33 

Figure 3 Change (a) and total number (b) of road fatalities per million population in the 27 EU countries (2010-
2019), reference year 2010 

(a) 

(b) 

Source: CADAS Data (2019) 

33   Charlton J et al. (2010) Influence of chronic illness on crash involvement of motor vehicle drivers, Monash University Accident 

Research Centre. 

9 

 
 
 
 
 
 
 
 
 
 
 
                                                 
The persistently high number of traffic fatalities and serious road traffic injuries – which in part is 
due to too many dangerous and unfit drivers on EU roads – remains a major societal problem, causing 
human suffering and losses as well as unacceptable economic costs estimated at EUR 250 billion 
yearly, or 2% of GDP34. Between 2010 and 2019, the number of road deaths in the EU decreased by 
23% (from 29,600 to 22,800 fatalities per year) and the number of serious injuries by 20%35. The 
decrease  in  the  number  of  fatalities  has  been  heterogeneous  by  Member  State  (see  Figure  3). 
However, in 2019, road crashes in the EU still claimed 22,800 lives and left more than 1.2 million 
people injured. In 2020, some 18,800 people were killed on EU roads. Although that number was 
more  than  17%  below  2019,  this  high  annual  reduction  rate  was  heavily  influenced  by  an 
unprecedented drop in road traffic at the height of the COVID-19 pandemic36. In 2021, the number 
of fatalities increased to 19,800. 

According  to  five  interviewed  national  authorities,37  current  rules  at  national  level  are  satisfactory  and 
sufficient to deliver on the road safety targets established at the EU level. Two others,38 however, find them 
insufficient to reach EU road safety targets. Regarding the adequacy of physical and mental fitness rules in 
place in the EU, six Member State authorities39 consider that updating these rules is needed. 

Finally, it should be highlighted that according to the “Safe System Approach” referred to in section 
1.1, many factors have to be considered when analysing a road crash: the infrastructure, the vehicle, 
the  traffic,  the  driver  and  the  emergency  services.  In  that  context,  the  accurate  identification  of 
underlying  causes  depends  on  the  availability  of  relevant  information  gathered  in  the  process  of 
recording road fatalities or serious injuries. This difficulty is increased by the fact that crashes usually 
result from multiple causes, hence the limitations which are associated with the use of such data. 

2.1.2  Problem 2: Barriers to the free movement of people due to inadequate or unnecessary 

procedures for driving licences 

A limited number of unnecessary or unjustified procedures for obtaining the licence or exercising or 
maintaining driving rights in another EU country remains in place when drivers obtain, use, replace, 
renew,  or  exchange  driving  licences.  This  ultimately  hinders  their  free  movement  within  the  EU. 
According  to  the  evaluation,  some  measures  of  the  Directive  (such  as  the  concept  of  normal 
residence) have been difficult to apply and may have led to a high administrative burden or obstacles 
to free movement. In practice, citizens with well-documented driving rights that are confronted with 
such remaining barriers may remain without driving licences for up to 6 months or even longer. The 
evaluation noted progress towards digitalisation of driving licences in some Member States, but with 
limited effects in the absence of a European framework.  

In  addition,  ten  individual  complaints  addressed  to  the  Commission  have  shown  that  the  current 
Directive may, in certain cases, prevent  EU citizens from obtaining a driving licence in  countries 
where their knowledge of the local language is insufficient and where an interpreter is not authorised 
during  the  tests.  They  have  also  confirmed  problems  resulting  from  diverging  applications  of  the 
concept of normal residence. Moreover, several cases have been brought to the Court of Justice of 

34   Sustainable  and  Smart  Mobility  Strategy  –  putting  European  transport  on  track  for  the  future  https://eur-lex.europa.eu/legal-

content/EN/TXT/PDF/?uri=CELEX:52020SC0331&from=EN   

35   CADAS Data (2019) 
36   During  the  first  lockdown  of  April  2020,  ETSC  reported  a  70-85%  reduction  in  traffic  volumes  in  major  European  cities 

(https://etsc.eu/covid-19-huge-drop-in-traffic-in-europe-but-impact-on-road-deaths-unclear/) 

37   DE, FI, SI, SE, FR 
38   NL, BG 
39   DE, BG, NL, BE, SE, FR 

10 

 
 
 
                                                 
the European Union (hereinafter “the Court”) when drivers, whose driving licence was withdrawn, 
were abusing this situation or were facing disproportionate consequences for the offence committed.  

Furthermore, there are no common rules for the exchange of driving licences issued by third countries 
when the holder establishes his or her residence in the European Union, and the EU licences obtained 
in one Member State may cease to be valid in case this person transfers his or her residence to another 
Member  State.  For  example,  in  Sweden,  only  licences  issued  by  the  United-Kingdom,  the  Faroe 
Islands, Switzerland and Japan are exchanged, while Finland exchanges licences issued by more than 
100 countries.  

Finally,  several  Member  States40  have  introduced,  or  are  planning  to  introduce,  national  mobile 
(digital) driving licences without being accompanied by the issuance of a physical support (i.e. card). 
As the current Directive establishes the principle of mutual recognition only for physical licences, 
mobile  driving  licences  will  therefore  remain  valid  only  on  the  territory  of  the  issuing  State. 
Consequently, the current framework is an obstacle to reaping the benefits of digital transformation 
of road transport at European level and hinders free movement across the EU.  

Barriers to the recognition, the acquisition or the renewal of driving rights can socially and financially 
affect the life of the drivers concerned in a profound way. Though the issues at stake are limited in 
scope41, the impact on the affected citizens is extremely important. Several studies have identified 
the lack of car access as an important barrier to accessibility to, and uptake of, employment. Studies 
with such findings have been conducted in, amongst others, Belgium42, Czechia43, France44, Ireland45 
and Spain46. Other studies47 find a clear link between holding a driving licence, access to cars and 
gainful employment for young persons. 

In the open public consultation for this impact assessment, 59% of respondents (4,462 out of 7,532) 
indicated  that  removing  unjustified  obstacles  to  obtaining  driving  licences  (first  issuance)  in  the 
Directive  is  very  important.  A  lack  of  mutual  recognition  of  theoretical  driving  tests  is  another 
example of a possible obstacle to free movement, and indeed it was assessed as an important problem 
by  12  out  of  20  respondents  from  Member  State  authorities  in  the  survey.  Similarly,  regarding 
medical exams taken in one Member State and not being recognised in another Member State, 11 out 
of 20 respondents from national authorities considered it as an important problem. Likewise, 14 out 
of 20 respondents from national authorities find that applicants moving to another Member State and 

40   Already  available  (Spain,  Denmark,  Greece,  Poland,  Portugal)  and  under  consideration  (Austria,  Belgium,  Cyprus,  Estonia, 
Finland, Germany, Ireland, Italy, Lithuania, Luxembourg, Netherlands, Sweden) according to UNECE informal document 10 of 
13 September 2022 and consultation activities.  

41   EU residents do not usually face these barriers. It concerns only very specific situations. 
42   Fransen  K.,  Deruyter  G.,  De  Maeyer  P.,  The  impact  of  driver’s  licence  ownership  on  unemployed  job  seekers’  access  to  job 
openings: Assessing the driver’s licence at School project in Flanders, Case Studies on Transport Policy, Volume 6, Issue 4,2018, 
Pages 695-705, https://doi.org/10.1016/j.cstp.2018.08.008. 

43   Marada M., Květoň V. Transport supply and demand changes in relation to unemployment: Empirical evidence from the Czech 

Republic in a time of crisis. Tijdschrift Voor Economische en Sociale Geografie, 107 (2016), pp. 611-627. 

44   Cavaco S. et al. Contraintes spatiales et durée de chômage. Revue Française D'économie, 18 (2004), pp. 229-257. 
45   O'Connell P.J., McGuinness S., Kelly E. The transition from short- to long-term unemployment: A statistical profiling model for 

Ireland Economic and Social Review, 43 (2012), pp. 135-164. 

46   Matas A, Raymond JL, Roig JL (2010) Job accessibility and female employment probability: The cases of Barcelona and Madrid. 

Urban Studies 47: 769–787. 

47   Aretun, A., Nordbakke S., Developments in driver’s licence holding among young people. Potential explanations, implications 

and trends. VTI, Linköping Sweden 2014. 

11 

 
                                                 
not being able to take their licence in the Member State of residence as they do not speak the language, 
nor English, to be an important problem and a possible barrier to the free movement of citizens. 

Regarding driving licence tourism, the problem has significantly reduced with the introduction of 
RESPER (EU network for the exchange of information on driving licences) which enables authorities 
to verify if driving rights exist or have been revoked in another country. Regarding fraud and forgery, 
the fraudsters also benefit from the evolution of technologies and while the risk remains present, it is 
mainly linked to forged driving licences using the old models. The obligation of the current Directive 
for  all  driving  licences  to  comply  with  the  new  model  (plastic  card)  by  2033  is  expected  to 
significantly mitigate the issue.  

2.2  2.2 

What are the problem drivers? 

2.2.1  Problem driver  1: Drivers  with insufficient  skills, knowledge, experience  and/or risk 

awareness are present on EU roads 

Driving  involves  a  large  set  of  rather  diverse  skills,  in  particular  information  acquisition  and 
perceptual-motor coordination, anticipation and assessment of the traffic situation, risk estimation, 
setting safety margins, balancing the disparate attractions of speed and caution. Driving requires to 
master relatively easy skills, like vehicle handling, and also more complex cognitive skills48. Indeed, 
while  vehicle  handling  skills  are  relatively  easy  to  master  in  only  a  few  hours,  skills  such  as 
anticipation of potentially hazardous traffic situations require years of practice.  

For the period 2017-2020, for every 100,000 novice drivers49, there are 10 novice driver fatalities, 
whereas for every 100,000 experienced drivers50, there are just 3 experienced driver fatalities, based 
on most recent CARE data available from 18 EU countries51.  

The link between driving skills and knowledge and road safety is confirmed by research52. Inexperience 
and age are considered the main factors behind the high rate  of collisions involving  young and novice 
drivers.  Multiple  studies  demonstrated  that  a  lack  of  driving  experience  is  translated  into  a  greater 
probability of being involved in road crashes as well as of serious breaches of road traffic laws53, 54, 55, 56.The 
lack of driving experience, in terms of kilometres driven, affects the capacity to control adequately the 
vehicle in difficult situations and increases the tendency to commit operative errors (e.g. harsh braking or 
close following), and increases the probability to be involved in near crash events57. The evaluation58 and 

48   DaCoTA (2012) Novice Drivers, Deliverable 4.8j of the EC FP7 project DaCoTA https://www.dacota-project.eu 
49   Less than 5 years after obtaining the driving licence 
50   Between 10 and 20 years after obtaining the driving licence 
51   Austria, Bulgaria, Croatia, Denmark, Finland, France, Germany, Greece, Hungary, Italy, Latvia, Luxembourg, Poland, Portugal, 

Romania, Slovakia, Slovenia and Spain 

52   European Commission (2017), Study on driver training, testing and medical fitness. 
53   Alfonsi,  R.,  Ammari,  A.,  Usami,  D.  S.  (2018),  Lack  of  driving  experience,  European  Road  Safety  Decision  Support  System, 

developed by the H2020 project SafetyCube. Retrieved from www.roadsafety-dss.eu on 03/11/2021 

54   Massie, D. L., Green, P. E., & Campbell, K. L. (1997). Crash involvement rates by driver gender and the role of average annual 

mileage. Accident Analysis & Prevention, 29(5), 675-685. 

55   Li, G., Braver, E. R., & Chen, L. H. (2003). Fragility versus excessive crash involvement as determinants of high death rates per 

vehicle-mile of travel among older drivers. Accident Analysis & Prevention, 35(2), 227-235.  

56   Maycock, G. (1985). Accident liability and human factors – researching the relationship. Traffic Engineering and Control, 26(6), 

330-335. 

57   Simons-Morton, B. G., Ouimet, M. C., Zhang, Z., Klauer, S. E., Lee, S. E., Wang, J. & Dingus, T. A. (2011). Crash and risky driving 

involvement among novice adolescent drivers and their parents. American Journal of Public Health, 101(12), 2362-2367. 

58   Evalution of Directive 2006/126/EC of the European Parliament and of the Council of 20 December 2006 on driving licences SWD (2022) 17 

final 

12 

 
                                                 
the implementation report59 highlighted that the missing element in current driver training and testing was 
risk awareness and hazard preparation exercises. In addition, training drivers to be able to use efficiently the 
state-of-the-art safety-related technologies that will also protect other road users (e.g., pedestrians, cyclists, 
riders  of  powered  two  wheelers)  is  also  missing.  In  the  public  consultation  underpinning  this  impact 
assessment60, 3,358 out of 7,532 (44%) respondents considered improving drivers’ skills and knowledge in 
the Directive as extremely/very important and 2,829 out of 7,532 respondents (37%) as important. This 
view was concurred by Member State authorities in the survey, where 19 out of 32 respondents in this group 
(59%)61 agreed that insufficient driving experience and/or risk awareness, in particular of novice drivers, is 
a very important problem for road safety.  

In addition to the case of novice drivers, drivers need skills and knowledge when driving new vehicles 
which include advanced technologies that assist the driver and aim at improving road safety. The maturity 
of  technologies  does  not  presently  allow  for  them  to  totally  replace  the  driver.  Additional  skills  and 
knowledge are required to ensure an effective and safe use of these technologies, starting with advanced 
driving assistance system (such as advanced breaking systems or intelligent speed assistance), but also 
preparing for the use of more advanced vehicle automation. Multiple studies 62,63,64 have also confirmed 
that  over-reliance  and  inappropriate  use  of  ADAS  have  been  highlighted  as  a  safety  risk  reducing 
effectiveness of various ADAS systems, which could be mitigated through training. During the targeted 
interviews, seven Member State authorities65 expressed the need for updating the rules to account for new 
technologies,  such  as  autonomous  driving,  ADAS,  eco-driving,  the  ability  to  use  navigation  and  the 
knowledge related to alternatively fuelled vehicles. In the targeted survey among national authorities, 16 
out  of  30  respondents66  assessed  insufficient  skills  and  knowledge  of  drivers  concerning  new  safety 
technologies as important for road safety, and only 2 respondents did not consider it a problem.  

Moreover, the vehicle categories  no longer fully match the market situation which has evolved, resulting 
in insufficient skills and knowledge of certain drivers. For instance, a licence of category AM is required 
to drive a moped while this is not the case for an e-scooter, even if both vehicles have a maximum design 
speed above 25 km/h. In addition, during the first workshop, UITP67 has reported the evolution of the 
market  offer  regarding  minibuses.  They  are  now  able  to  carry  up  to  22  passengers  (16  currently  for 
category D1) while their length remains below 8 meters. CEETTAR has also indicated the differences 
among national licences for agricultural vehicles, which is an issue for posted workers.   

2.2.2  Problem driver 2: Drivers with dangerous behaviour are present on EU roads 

ETSC reports that exceeding speed limits and drink driving are among the important factors leading to 
death and serious injury on European roads, along with failing to wear seatbelts. 68 Furthermore, findings 
from a recent study indicated that speeding drivers as well as drivers driving under the influence (DUI) 
of  alcohol  or  drugs  were  frequently  involved  in  single-vehicle  crashes  under  low-volume  conditions 

59   ‘The implementation of Directive 2006/126/EC on driving licences – Final report’ by Hasselt University et al,, 2017 

http://publications.europa.eu/resource/cellar/bbd8141d-e603-11e7-9749-01aa75ed71a1.0001.01/DOC_1  

60   COWI, Ecorys and NTUA (2022), Impact assessment support study 
61   More than one authority responded from some Member States, thus the number of 32 respondents. 
62   https://etsc.eu/us-study-shows-drivers-let-their-focus-slip-as-they-get-used-to-driver-assistance-systems/  
63   https://aaafoundation.org/understanding-the-impact-of-technology-do-advanced-driver-assistance-and-semi-automated-vehicle-

systems-lead-to-improper-driving-behavior/  

64   https://www.fiaregion1.com/wp-content/uploads/2020/10/FIA-Region-I-_ADAS-study_18122020.pdf  
65   DE, BE, NL, BG, FI, SE, FR 
66   More than one authority responded from some Member States, thus the number of 30 respondents. 
67   https://www.uitp.org  
68   https://etsc.eu/wp-content/uploads/ETSC_PINFLASH42_v2TH_JC_FINAL_corrected-060522.pdf  

13 

 
                                                 
(night-time, weekend, low-volume roads). 69 During the period 2016-2020, 41% of total driver fatalities 
in Europe concerned single-vehicle road crashes, mainly due to dangerous behaviour70. For the same 
period  2016-2020,  50%  of  novice  driver  (18-24)  fatalities  concerned  single-vehicle  road  crashes71. 
Statistics also show that men are mainly affected by the problem of drink-driving.72 Considering these 
findings, the great majority of single-vehicle crashes occur as a result of dangerous behaviour.  

The consequence of a road traffic offence on the offender’s driving licence differs very much across 
the  EU,  depending  on  the  country  of  issuance,  residence  and  offence.  A  driving  licence  can  be 
suspended  or  withdrawn  when  its  holder  commits  serious  road  traffic  offences.  However,  this 
decision can only be taken by the State of issuance or State of residence73. When a person commits 
such an offence abroad, he or she is banned from driving only in that country (the State of offence). 
In such a situation, a dangerous driver can continue to drive in all EU Member States apart from the 
State of offence and still poses a threat to road safety in those countries. 

Based on an amendment of the DL  Directive adopted in 2018, RESPER can also  be used for  the 
purpose of  control,  however  exchanges in  the  context  of the Committee on driving  licences have 
shown that the 2018 amendment to the Directive does not specify the use cases for law enforcement 
in a way that allows for a clear mapping with the practices on the field. It creates a risk that certain 
uses of RESPER by law enforcement authorities could be challenged before the Court. In addition, 
these consultation activities have shown that the response time is not always satisfactory, and the data 
quality could be improved. 

The  share  of  speeding  offences  committed  by  drivers  in  foreign  vehicles  differs  greatly  across 
Member States. For example, holiday and transit countries (e.g. Austria, Luxembourg and France) 
attract a lot of non-resident drivers, while the more remote countries are likely to attract less foreign 
traffic. Although the share of detected offences with foreign registered vehicles differs significantly 
between Member States (Hungary 91%, Luxembourg 42%), on average around 18% of all speeding 
offences are committed by drivers in foreign vehicles. This means that there is a material group of 
drivers  who  commit  serious  traffic  offences  in  other  Member  States  but  are  not  (fully)  held 
accountable for them. The investigation of offenses potentially resulting in driving disqualifications 
committed by non-residents  is  not covered by the CBE Directive.  The procedural  steps included 
therein only cover measures that can facilitate the identification of the offender and measures related 
to the content of information that the identified person (mostly the owner or holder of the vehicle) 
must receive and the language of this information. The revision of the CBE Directive aims to improve 
enforcement through measures related to investigation and better identification of offenders, and to 
improve the protection of the fundamental and procedural rights of the offender. However, it will not 
provide the necessary legal basis for the mutual recognition of driving disqualifications. 

The  evaluation  of  the  Driving  Licence  Directive74  concluded  that  the  absence  of  a  clear  EU 
framework for the mutual recognition of driving disqualification poses challenges when it comes to 
preventing abuses by drivers that commit offences on the territory of one Member State but then can 
continue to drive in other Member States without bearing consequences of the offences. This was 
corroborated by the views of 16 out of 21 respondents representing national authorities who saw the 

69   Speeding and impaired driving in fatal crashes-Results from in-depth investigations - PubMed (nih.gov) 
70   Based on most recent CARE data available from 25 EU countries (all but Cyprus and Ireland) 
71   ibid 
72   https://etsc.eu/83-of-drink-drivers-are-men/  
73   In that later case, the Directive  allows the  state of residence to proceed with the automatic exchange of the driving licence in 

accordance with its police and judicial laws 

74   https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX%3A52022SC0017  

14 

 
                                                 
fact that residents and non-residents in the EU do not face the same consequences regarding driving 
disqualification  as  a  generally  important  problem.  Also,  respondents  identified  as  an  important 
problem  the  fact  that  residents  and  non-residents  do  not  face  the  same  consequences  regarding 
penalty/demerit  points  (11  out  of  21  respondents).  When  asked  about  the  absence  of  a  mutual 
recognition of driving disqualification, some Member States75 confirmed that it renders difficult the 
enforcement  of  disqualification  across  borders  and  hence  poses  a  risk  to  road  safety  in  the  EU, 
especially in cases where the banning from driving resulted from serious offences (e.g. driving under 
the influence of alcohol among others). 

2.2.3  Problem driver 3: Drivers that are not physically or mentally fit to drive are present on 

EU roads 

According to results of the survey conducted in the context of the support study, a range of 5-15% of 
all traffic accidents were attributed to driver’s medical condition. This range is confirmed by multiple 
sources: the ETSC PIN Flash Report 40 (2021) indicates that, in Finland, 16% of all fatal collisions 
are  attributed  to  a  driver  illness76.  In  France,  close  to  4%  of  total  accidents  was  attributed  to 
medication77. A Danish report78 revealed that, during the period 2017-2019, 9% of traffic accidents 
was attributed to impaired physical conditions and 1% to an unbalanced state of mind79. Ageing is an 
important factor when considering the mental and physical ability to drive. Elderly drivers are more 
prone to be involved in a car accident.80 Currently, more than 20% of road fatalities in the EU are 
caused by drivers over 60 years old, while they represent approximatively 30% of all licence holders. 
In particular, the presence of cognitive dysfunction due to the ageing process, especially in the case 
of  neurocognitive  disorders  of  high  prevalence,  such  as  Alzheimer’s  disease,  may  critically 
compromise  a  person’s  fitness  to  drive81  82.  Finally,  apart  from  functional  limitations,  physical 
vulnerability is also a factor which contributes to the relatively high fatality rate and increased crash 
severity for elderly road users in road crashes.83 

In the survey among national authorities84, 8 out of 22 respondents (36%) considered the problem of 
inadequate medical screening of all drivers as important, while 4 out of 22 (18%) did not identify it 
as  a  problem  for  road  safety.  10  out  of  22  respondents  (45%)  from  other  groups  of  stakeholders 
considered that insufficient medical screening constitutes an important or very important problem for 
road safety. Overall, stakeholders other than national  authorities argued that the focus on medical 
requirements in Annex III of Directive 2006/126/EC is too narrow and that there is a lack of clinical 
guidelines  and  scientifically  validated  criteria.  They  believed  that  the  focus  should  be  placed  on 
functional requirements to drive rather than age-related requirements and argued that there should be 
a standardised set of procedures for screening medical fitness to drive across the EU to help medical 
professionals detect medical/fitness to drive issues.  

75   BG, SE, BE 
76   https://etsc.eu/wp-content/uploads/PIN-Flash-40_Final.pdf  
77   La sécurité routière en France : Bilan de l’accidentalité de l’année 2019 
78   Ulykkesfaktorer in Vejdirektoratet (2020) Dødsulykker 2019 Årsrapport 
79   https://www.statistik.at/fileadmin/publications/Strassenverkehrsunfaelle-2021.pdf  
80   Oxley, J., Corben, B., Fildes, B., O'Hare, M., & Rothengatter, T. (2004). Older vulnerable road users- measures to reduce crash 

and injury risk. Monash University Accident Research Centre Reports, 218, 162. 

81   Jacobs M., Hart E. P., Roos R.A.C. (2017). “Driving with a neurodegenerative disorder: an overview of the current literature”, 

Journal of Neurology, Volume 264, p. 1678-1696. 

82   Pavlou, D., Beratis, I., Papadimitriou, E., Andronas, N., Kontaxopoulou, D., Fragkiadaki, S., Yannis, G., Papageorgiou S.G. (2017) Mild Cognitive 
Impairment and driving: Does in-vehicle distraction affect driving performance? Accident Analysis and Prevention, Volume 103, p. 148-155. 
83   European Commission, Older Drivers, European Commission, Directorate General for Transport, September 2015  https://road-

safety.transport.ec.europa.eu/system/files/2021-07/ersosynthesis2015-olderdrivers25_en.pdf  

84   COWI, Ecorys and NTUA (2022), Impact assessment support study  

15 

 
                                                 
During the interviews85, Member States authorities86 expressed the need for changes to  minimum 
standards  for  physical  and  mental  fitness  to  drive.  In  the  survey,  most  respondents  from  national 
authorities  (68%  or  15  out  of  22)  acknowledged  the  insufficiency  or  inadequacy  of  standards  for 
medical fitness as a problem. This view was concurred by respondents other than national authorities 
who  considered  insufficient  or  inadequate  standards  on  physical  and  mental  fitness  to  be  a  very 
important  (24%)  or  important  (44%)  problem  for  road  safety.  Regarding  the  age-related  medical 
screening,  some  Member  States87  during  the  interviews  did  not  think  of  aging  as  a  problem  and 
opposed the idea that more frequent medical screening for older drivers would be needed. According 
to one Member State88, this would in fact restrict elders’ right to mobility too soon. Another MS89 
instead remained open to the idea of limiting older drivers’ mobility under certain conditions (e.g., 
driving during the night, a limit of kilometres that can be driven). 

However, while there is evidence about the potential physical deterioration connected with age, some 
studies have concluded that specific medical conditions, such as substance abuse, mental disorders, 
epilepsy and diabetes, heart conditions and sleep apnoea are not necessarily connected with age. At 
the  same  time,  they  are  more  important  factors  when  it  comes  to  medical  fitness  to  drive.90 
Consequently,  mandatory  age-based  screening  of  drivers  has  not  been  shown  to  be  effective  in 
preventing severe collisions.  

2.2.4  Problem  driver  4:  Applicants  face  difficulties  to  obtain  a  driving  licence  due  to 

inadequate or unnecessary procedures 

Complaints  addressed  by  citizens  to  the  Commission91,92,  the  ex-post  evaluation  and  consultation 
activities in the frame of this impact assessment have shown that obtaining a driving licence may be 
hindered by inadequate or unnecessary procedures.  

The current rules under the DL Directive on normal residence provide for a strong framework to fight against 
fraud but may not be fully adequate anymore due to the changes in mobility patterns within the EU during the 
past two decades.  

The Directive (Article 12) defines normal residence as “the place where a person usually lives, that is for at 
least 185 days in each calendar year, because of personal and occupational ties, or, in the case of a person 
with no occupational ties, because of personal ties which show close links between that person and the place 
where he is living”. It allows to determine the Member State competent to issue a driving licence for a person. 
The conditions of establishment of a normal residence differ however from one Member State to another and 
are mainly linked to national fiscal rules, but also the respective registration rules. In addition, the normal 
residence may also be determined based on the personal ties of the person, irrespective of his or her place of 
residence. The current concept results in a situation where a person can have multiple normal residences or 
where the normal residence cannot be identified (usually during the six first months after a person relocates 

85   COWI, Ecorys and NTUA (2022), Impact assessment support study 
86   DE, BG, NL, BE, SE, FR 
87   DE; FR,SE 
88   DE 
89   FR 
90   Charlton J et al. (2010) Influence of chronic illness on crash involvement of motor vehicle drivers, Monash University Accident 

Research Centre. 

91   CHAP (Complaints Handling – Accueil des Plaignants) is the Commission IT tool for registering and managing complaints and 

enquiries by European citizens or businesses concerning the application of EU law by a Member State. 

92   SOLVIT (Solutions to problems with your EU rights) is a service provided by the national administration in each EU country and 
in Iceland, Liechtenstein and Norway. SOLVIT aims to find solutions within 10 weeks – starting on the day your case is taken on 
by the SOLVIT centre in the country where the problem occurred. 

16 

 
                                                 
from one MS to another). During interviews, when asked about whether the current implementation of normal 
residence in Member States impacts the free movement of people in the European Union, most interviewed 
Member State authorities found the definition of normal residence problematic, to the extent that some93 called 
for guidance or a clarification of normal residence from the EU to ensure uniform application of the principle. 
Other Member States94 reported issues with residents caught in between Member States, who cannot apply (or 
renew) for a licence in the Member State they are living as normal residents nor in their new Member State as 
they  have  not  passed  the  185-days  threshold  in  that  country.  The  importance  of  the  problem  was  also 
confirmed by 12 out of the 20 representatives of national authorities responding to the survey.  

Difficulties may also occur when a person establishes his or her normal residence in another Member 
State and should pass the tests in the new country of residence, while that person does not have a 
sufficient level of skills of the languages available for the tests. It is especially true when national 
rules do not allow for an interpreter and when no/limited tests in another language are provided. Such 
a situation arises in particular in the case of the theoretical tests for which the testing time is limited 
and questions require an advanced knowledge of the language used. It may also affect practical tests 
when a quick reaction is expected. The impact assessment support study95 has shown that in 2021, 
there were  between  40,000 and 80,000 potential  applicants  that could not  conduct  the test due to 
language barriers. This language issue was generally perceived as an important problem by 14 out of 
the 20 respondents representing national authorities in the survey, although to different degrees. This 
was however seen as less of a problem when applicants for graduated access for motorcycles have to 
pass through cumbersome and costly procedures to obtain their licence (7 out of 20 respondents).  

Additionally, existing rules limit the right to drive vehicles with an automatic transmission gear only when 
the  test  has  been  passed  on  such  a  vehicle.  A  procedure  for  extending  the  right  to  drive  also  manual 
transmission  gear  vehicles  once  a  licence  for  automatic  transmission  gear  vehicles  is  obtained  is  not 
foreseen. Consequently, the holder of a driving licence subject to this restriction has to undergo the complete 
curriculum required from any applicant, including the driving test, to have the restriction removed. With the 
progressive electrification of the car fleet and the phasing out of conventional fuel vehicles, and in particular 
the  proposed phasing  out  of  new  conventional  fuel  cars  and  vans (part of the  “Fit  for  55” package96), 
automatic  transmission  gear  is  expected  to  be  the  norm  in  new  vehicles  in  the  future.  Certain  vehicle 
manufacturers also indicated that they are even considering to stop placing on the market new vehicles with 
manual transmission gear earlier than previously thought97,98. By 2030, around 15% of the car fleet is 
projected to be equipped with automatic gear transmission, going up to over 90% by 2050.  

Moreover, the lifetime of vehicles in driving schools is usually of 2 or 3 years99 and, thus, it is expected that 
the fleets of driving schools will change to automatic transmission gear vehicles much faster than the overall 
fleet. Therefore, the existing DL Directive does not seem sufficiently aligned with the European Climate 
Law and with technological developments. In the survey100, respondents from national authorities were 
divided on this issue: 8 out of 20 respondents did not consider it a problem, whereas 7 did consider it as an 
important problem to different degrees. Respondents outside the national administration were slightly more 
convinced that this could be a problem, 9 out of 22 respondents identified the issue of drivers tested on 

93   BE, BG, SE, FI 
94   NL, BE 
95   COWI et al. (2022), Impact assessment support study for the revision of the directive on driving licences 
96   Delivering the European Green Deal | European Commission (europa.eu) 
97   Articles of Auto Motor Sport 
98   Articles of Automobilwoche  
99   Lesauto kost rijschoolhouder 8 euro per lesuur | RijschoolPro 
100  COWI, Ecorys and NTUA (2022), Impact assessment support study 

17 

 
                                                 
automatic gear not being allowed to drive a manual gear unless they pass another examination to be an 
important problem.  

Another  obstacle  resulting  from  the  transition  to  zero-emission  vehicles  is  related  to  their  mass.  The 
increased mass of some of these vehicles (e.g. because of batteries) may exceed the maximum mass of 
vehicles authorised to be driven with a driving licence of category B and require a licence of category C.  

Finally,  the  consultation  activities  have  underlined  that  road  transport  operators  consider  the 
minimum age for categories C and D (18 and 21 years) an obstacle for pupils leaving the school at 
16 years old to access the profession of drivers because of the resulting time to obtain a licence, which 
is too long. The 2022 report101 of the International Road Transport Union (IRU) on the shortage of 
drivers identifies for 2021 3 million truck drivers and 425 thousand unfilled positions, as well as 234 
thousand  bus  and  coach  drivers  and  30  thousand  jobs  unfilled.  One  third  of  current  professional 
drivers are 55 years old or more. They are expected to retire in the coming years. In parallel, young 
people (25 years and below) represent only a very limited share of professional drivers (3% for buses 
and coaches, 7% for trucks). While the underlying causes for the shortage of drivers are related to 
many  other  issues  which  negatively  affect  the  attractiveness  of  the  profession,  road  transport 
operators report that the minimum age to obtain a driving licence presents an obstacle for some of 
out-of-school young people, considering that compulsory school obligation ends often at 16 years. 
Indeed, training curricula and/or waiting times for access to the driver profession appear significantly 
longer than for other professions.  

According to EUROSTAT 2020 data, there are 545,000 out of school young people aged 16 or 17 
years in the EU. It is not possible to assess the share of young people that would decide to become a 
professional  driver  but  an  estimate  of  5%  applied  to  young  people  out  of  school  would  result  in 
27,000 new drivers if the minimum age for category C/D was decreased to 16 years (respectively 
13,500 for a minimum age of 17 years). While it cannot be concluded that the access to the profession 
due  to  long  training  and  age  limitations  is  one  of  the  main  underlying  causes  of  the  shortage  of 
professional  drivers,  considering  how  critical  the  shortage  of  drivers  is  becoming  and  the  likely 
effects on the functioning of the internal market, reducing the minimum age cannot be disregarded 
as a complementary measure that could contribute to mitigating the issue of driver shortage. 

2.2.5  Problem  driver  5:  Holders  of  licences  face  difficulties  to  have  their  driving  rights 
maintained  or  recognised  in  cross-border  context  due  to  inadequate  or  unnecessary 
procedures  

The  ex-post  evaluation  has  shown  that  the  current  rules  may  not  be  adequate  regarding  certain 
specific  aspects  of  the  recognition  or  maintenance  of  driving  rights.  The  open public  consultation 
confirmed these findings, as removing obstacles to renewing, replacing or exchanging driving licences 
issued by  EU/EEA  Member States  was  perceived  as extremely  or very  important to the  respondents 
(4,428 out of 7,532 respondents, or about 58%). Also, removing of obstacles to renewing, replacing or 
exchanging  driving  licences  issued  by  non-EU  countries  was  considered  as  either  extremely/very 
important (3,612 out of 7,532 respondents, or 48%) or important (1,818 out of 7,532 respondents, or 
24%).  

Firstly,  the  same  issues  apply  regarding  the  national  implementing  rules  to  establish  the  normal 
residence of a person as for problem driver 4. It concerns a person unable to have a normal residence 
identified who is therefore not in a position to renew his or her driving licence in the event of a loss 

101  https://www.iru.org/resources/iru-library/driver-shortage-european-report-2022   

18 

 
                                                 
or  a  theft.  It  concerns  also  persons  having  two  or  more  normal  residences  who  may  abuse  this 
situation to avoid the consequences of road traffic offences.  

Secondly, the current rules provide the optional possibility for driving a motorcycle of category A1 
with a licence of category B but  the resulting rights are only valid on the territory of the State of 
issuance.  Complaints  addressed  by  citizens  to  the  Commission  and  the  European  Parliament 
questioned  the  limitation,  especially  in  case  of  two  countries  applying  this  same  optional 
equivalence102.  

Thirdly, the mutual recognition of driving licences established by the DL Directive is strictly limited 
to physical documents. Digital transformation has improved the daily life of citizens and has become 
a tool for administrative simplification. Currently, five Member States103 allow for the possibility to 
hold a driving licence in digital format. Many other Member States have initiated projects to deliver 
similar services. Under the current DL Directive, these digital licences are not mutually recognised 
and therefore remain valid on the territory of the issuing State only. A citizen with a digital driving 
licence wanting to drive in another Member State needs to carry the physical licence (card). In this 
context, citizens are not able to fully reap the benefits of the digital transformation. The same applies 
to administrations both when issuing driving licences and for the purpose of enforcement. 10 out of 
18 respondents to the survey104 among national authorities considered the fact that drivers cannot 
make use of their digital driving licence when driving on the territory of another Member State a 
problem. Only one respondent did not consider it a problem. Interviewed Member States105 generally 
agreed that the lack of mutual recognition of mobile driving licences impacts the free movement of 
those EU drivers that currently hold one. According to two Member States106, the fact of having to 
carry both a physical and digital driving licence when driving across the EU means that drivers have 
to bear additional costs. In the survey, 7 of the 22 respondents not belonging to national authorities 
considered the fact that drivers cannot make use of their mobile driving licence when driving on the 
territory  of  another  Member  State  as  an  important  problem  and  4  of  22  respondents  as  a  very 
important problem that imposes unnecessary administrative burden and costs on drivers.  

Fourthly, as regards driving disqualifications in case the offender changes residence, the Court has held that 
outside of an explicit period of prohibition on applying for a new driving licence, if drivers change their 
normal residence and apply for a new driving licence, their new licence must be recognised in all Member 
States, and even in a Member State that imposed a driving disqualification on them previously107. Whether 
the condition of normal residence was fulfilled can only be assessed by the Member State of issuance. 
Therefore, other Member States can only refuse to recognise the validity of the new driving licence within 
their territory based on non-compliance with the normal residence criteria, if it is established based on entries 
on the driving licence or other indisputable information from the issuing Member State that such condition 
has not been satisfied108. 

Moreover, holders of EU driving licences who moved to overseas territories of EU Member States 
and hence changed their normal residence, are also often not able to drive in a Member State other 

102  One example is the case of holders of category B licences being authorised to drive light motorcycles in Germany or Austria but 

only on the territory of the state that has issued the licences 

103  Poland, Portugal, Greece, Spain and Denmark 
104  COWI, Ecorys and NTUA (2022), Impact assessment support study 
105  BG, BE, NL, FR, SI, FI, DE 
106  BE, NL 
107  Case C-419/10, Hofmann, ECLI:EU:C:2012:240 
108   See for example: Case C‑467/10, Akyüz, ECLI:EU:C:2012:112, paragraph 62 

19 

 
                                                 
than the one the territory depends on because of the limitations of the driving licence issued by this 
overseas territory (e.g. Danes from Greenland who can only drive in Denmark and Greenland). 

Finally, three types of issue concern driving licences issued by third countries 

-  The holder of a driving licence issued by a third country is subject to different rules, depending 
on  the  Member  State  where  he/she  establishes  his/her  residence  in  the  EU.  Indeed,  in  certain 
Member States, he/she may be able to obtain an EU driving licence by means of an administrative 
exchange while in others, he/she will have to pass the theoretical and practical tests. 11 of the 22 
respondents from national authorities in the stakeholder survey considered the issue of third countries’ 
driving licence holders who encounter difficulties in exchanging their licence in Member States as an 
important problem. 

-  EU driving licences  issued in  exchange of a  third-country  driving licence are  marked with  the 
harmonised  Union  code  70.  This  code  restricts  the  rights  of  the  holder  in  case  he/she  later 
establishes his/her residence in another EU Member State. The new Member State of residence 
may refuse to recognise and exchange the EU driving licence with a code 70109. In that case, the 
holder would have to  pass  the theoretical  and practical  tests  to  maintain  his/her driving rights. 
During the workshop of 22 April 2022, most of the Member States and stakeholders have acknowledged 
that this hampers the free movement of persons while road safety is very unlikely to be at risk. 

-  A driver who passed the driving test in the EU may not be able to regain his/her EU driving licence 
if he/she leaves the EU, exchanges his/her EU driving licence for a foreign one and returns in an 
EU Member State other than the one where he/she passed the driving test. The current EU rules 
do not create an obligation on that Member State to consider the rights previously acquired in the 
EU.  Consequently,  these  persons  are  likely  to  be  required  to  pass  the  driving  test  again  if  an 
exchange is not possible. This problem has been raised several times in SOLVIT and has been 
confirmed by the competent authorities.  

2.3  2.3 

How likely is the problem to persist? 

2.3.1  Problem 1: High number of unfit drivers on EU roads.  

Without  further  EU  level  intervention,  the  high  number  of  unfit  drivers  on  EU  roads  is  likely  to 
persist.  New  vehicles  will  incorporate  advanced  safety  technologies:  from  7  July  2024,  all  new 
vehicles will be required to have certain safety technologies installed in accordance with the General 
Safety Regulation  (Regulation  (EU) 2019/2144).  Other safety technologies will follow later (July 
2026  /  January  2029).  Member  States  may  adapt  the  content  of  the  tests  while  remaining  in 
compliance with the EU rules. However, without a general focus on these technologies, drivers’ skills 
will be only partially adapted and drivers may lack training to safely operate them. In addition, by 
2030, around 15% of the car fleet is projected to be equipped with automatic gear transmission, going 
up to over 90% by 2050. The current rules, relevant for a fleet mainly consisting of vehicles with 
manual  gear  transmission,  will  be  rapidly  outdated.  While  Member  States  may  adopt  certain 
simplifications applicable on their national territory to address this issue, these solutions may result 
in additional obstacles to the free movement of people and goods.   

Moreover, the vehicle fleets will remain heterogeneous and the initially lower levels of automation 
will still require the driver’s intervention in case of a risky road situation. The ageing of the population 
will  on the  one  hand  contribute  to  fewer  fatalities  due  to  the  lower  share  of  young  drivers  in  the 

109   Usually  the  exchange  is  possible  only  if  the  new  state  of  residence  exchanges  driving  licences  issued  by  the  concerned  third 

country.   

20 

 
                                                 
overall driver population, but on the other hand it will likely result in an increase in the number of 
drivers that are physically or mentally unfit to drive.  

Finally, in absence of further EU level intervention, the behaviour of drivers will not significantly 
improve. The number of offences committed abroad will likely decrease by 2040 due to the gradual 
introduction of new safety features in the vehicle fleet, based on the General Safety Regulation110. 
However, as the effect of the introduction of new safety features in the vehicle fleet is expected to 
peter out by 2040, the number of detected offences is projected to increase again post-2040. Member 
States could  in  theory  establish bilateral  or multilateral  frameworks for the mutual  recognition  of 
driving  disqualifications  or  simply  rely  on  information  exchanged  within  RESPER  to  enforce 
sanctions on holders of a driving licence issued by their authorities when an offence is committed 
abroad. However, the set-up would be sub-optimal, notably because of the complexity to achieve a 
complete  European  geographical  coverage  and  the  risk  of  different  rules  and  rights  applicable  to 
drivers. In the past, multiple Conventions (1964, 1976) tried to address the issue in the framework of 
the  Council  of  Europe.  However,  they  were  not  ratified  by  enough  Member  States  to  result  in  a 
significant impact. 

In this context, the number of fatalities is projected to decrease by 3% by 2030 relative to 2020 (15% 
reduction for 2020-2050) and the number of serious injuries to remain relatively stable by 2030 (10% 
decrease  for  2020-2050).  Neither  the  50%  reduction  of  fatalities  by  2030,  nor  zero  fatalities  on 
European roads by 2050 will be achieved. 

2.3.2  Problem 2: Barriers to the free movement of people due to inadequate or unnecessary 

procedures for driving licences.  

Without further EU level action, applicants will continue to experience difficulties in obtaining their 
driving licences in Member States other than the Member State of origin, due to the barriers and extra 
costs related to the knowledge of the local language when taking a driving exam in another Member 
State,  to  different  medical  fitness  practices  and  to  different  requirements  by  Member  States  for 
accessing driving licences. The problem is expected to persist also in relation to the establishment of 
normal residence and the misalignment of the provisions related to automated transmission and to 
the maximum mass of vehicles that can be driven with a category B licence, given the increasing 
number of electric vehicles that are generally heavier.  

In addition, holders of driving licences will likely continue to see their driving rights limited because 
of the lack of mutual recognition of certain rights entrusted by driving licences, and the additional 
costs  they  have  to  bear  when  moving  to  another  Member  State,  resulting  from  the  change  of 
administrative validity periods and the need for additional medical fitness checks. Holders of driving 
licences  will  likely  also  continue  to  experience  difficulties  renewing  or  exchanging  their  driving 
licences in other Member States due to divergent interpretations of ‘normal residence’ and the lack 
of a uniform approach to check ‘normal residence’ across Member States. 

The  number  of  Member  States  issuing  mobile  driving  licences  is  expected  to  increase  over  time. 
Without further EU level action, drivers holding mobile driving licences will however not be able to 
fully benefit from the advantages as the validity of the digital licence will be limited to the territory 
of the Member State issuing it. Drivers will therefore continue to see their freedom of movement 
restricted in case they only carry a digital driving licence. 

110  Regulation (EU) 2019/2144 

21 

 
                                                 
Finally, regarding the shortage of professional (bus, coach and truck) drivers, the current rules on 
minimum age result in an earliest entry into the profession at 18 years.  

With costs remaining an obstacle to the modal shift away from road operations and the automation 
of vehicles, it is expected that the shortage of professional drivers will remain a relevant issue in the 
long  term.  This  trend  is  confirmed  by  the  increase  in  traffic  as  illustrated  in  the  Staff  Working 
Document accompanying the Sustainable and Smart Mobility Strategy (section 5)111 and the increase 
of the demand for commercial road transport reported by IRU112. 

2.3.3  Foresight 

The  analysis  incorporates  throughout  all  its  dimensions  relevant  foresight  tools.  It  does  so  to 
anticipate trends and issues that may affect the initiative and build a robust, future-proof evidence 
base for its likely impact. Megatrends113 and strategic foresight report findings114 are used throughout 
the problem definition, baseline, policy objectives and options sections of the document. 

The megatrend “Accelerating technological change and hyperconnectivity” will affect significantly 
the problem affecting road safety with the progressive introduction of automation and connectivity 
in the sector of road transport. International policy work is still on-going regarding automated driving, 
in particular in the context of the UN Economic Commission for Europe115. The ex-post evaluation 
has identified the need to update the standards on skills and knowledge to be met in order to obtain a 
driving licence. Moreover, the 2022 Strategic Foresight Report points to the potential of future digital 
technologies to render road transport more efficient and sustainable, if used properly116. For example, 
the  use  of  data  from  vehicles  and  their  environment  can  optimise  charging.  This  in  turn  requires 
training driving licence holders to use new technologies as they reach the market. 

Another megatrend that impacts how the problems will likely evolve is “Shifting health challenges”. 
As Europeans are living longer and healthier lives, the challenges that come with it affect their fitness 
to drive at different ages. This has been taken into account in the analysis in the following sections.  

Finally, the significance of migration is changing too. In 2020, an estimated 281 million people were 
living outside their country of birth worldwide.117 As their numbers are higher than ever and continue 
to grow, the problems related to obtaining or exchanging driving licences outside one’s country of 
origin will continue to persist and possibly worsen. 

3 

3  WHY SHOULD THE EU ACT? 

3.1  3.1 

Legal basis 

Title VI (Articles 90-100) of the Treaty on the Functioning of the EU (TFEU) establishes the EU’s 
prerogative to make provisions for the Common Transport Policy. Article 91(1)(c) TFEU provides 
that the European Union has competence in the field of transport to lay down measures to improve 

111  EUR-Lex - 52020SC0331 - EN - EUR-Lex (europa.eu) 
112  Europe driver shortage to triple by 2026 if no action: new IRU report | IRU | World Road Transport Organisation 
113  https://knowledge4policy.ec.europa.eu/foresight/tool/megatrends-hub_en  
114  https://ec.europa.eu/info/strategy/strategic-planning/strategic-foresight_en  
115  https://unece.org/automated-driving#accordion_3  
116  COM(2022) 289 final. 
117  https://knowledge4policy.ec.europa.eu/increasing-significance-migration_en  

22 

 
                                                 
transport safety, while Article 91(1)(d) TFEU provides the same competence as regards “any other 
appropriate provisions”. 

It is the longstanding practice of the Court that the European Union enjoys broad legislative powers 
within  the  remit  of  the  common  transport  policy118 ,  and  most  of  the  policy  measures  clearly  fall 
within  the  scope  of  this  competence.  However,  in  the  case  of  mutual  recognition  of  driving 
disqualifications  (PM  4),  additional  legal  examinations  were  carried  out  in  order  to  determine 
whether Article 91(1) TFEU is the correct legal basis to adopt such measure on. It was concluded 
that Article 91(1) TFEU can be considered the correct legal basis, as long as the conduct is considered 
an offence, which is sanctioned with driving disqualification in both the Member State of the offence 
and the Member State of the normal residence (principle of ‘dual disqualification’). Furthermore, the 
legal examination concluded that it is not possible to use a dual legal basis, i.e. common transport 
policy legal basis together with the legal basis contained within Title V of Part Three of the TFEU 
(judicial and police cooperation). 

3.2  3.2 

Subsidiarity: Necessity of EU action 

Under the principle of subsidiarity, in areas which do not fall within its exclusive competence, the 
EU  shall  act  only  if  and  in  so  far  as  the  objectives  of  the  proposed  action  cannot  be  sufficiently 
achieved by the Member States. Matters related to driving licences contain transnational aspects that 
cannot  be  covered  by  individual  Member  States  alone.  While  the  DL  Directive  represents  an 
important  step  in  the  process  of  harmonising  the  rules  on  driving  licences  and  contributes  to  the 
implementation of Union policies, it has so far been amended eleven times to harmonise common 
standards and requirements, as well as to adapt the rules to the scientific and technical progress that 
has  occurred  since  2006.  The  Directive’s  2022  ex-post  evaluation  has  identified  the  need  for  its 
thorough review to ensure that all elements are in place to fulfil the policy objectives. 

In  light  of  the  EU  targets  on  road  safety  and  the  insufficient  progress  projected  in  reducing  road 
fatalities and serious injuries’, further EU action is needed to deliver on the set targets. For example, 
the fight against dangerous behaviour on roads can only deliver fully in case non-resident road traffic 
offenders face the same sanctions for their conduct as residents. 

EU level action is needed also to remove unnecessary and unjustified barriers to the free movement 
of people due to inadequate procedures for issuing and renewing driving licences. These problems 
need to be addressed at EU level because they have a cross-border dimension. A prominent example 
are the mobile driving licences which can only be mutually recognised across the EU if the solutions 
used by Member States are interoperable.  

3.3  3.3 

Subsidiarity: Added value of EU action 

The 2022 ex-post evaluation underlined the added value of the DL Directive, particularly in terms of 
its effectiveness and efficiency. The Directive is found to have had a positive effect on road safety, 
the  free  movement  of  EU  citizens,  the  reduction  of  driving  licence  fraud  and  of  driving  licence 
tourism, and it also led to a reduction of the administrative burden, in particular for driving licence 
holders.  

Without EU intervention, cooperation on driving licences between Member States would have continued 
probably  via  bi-  or  multilateral  agreements  which,  in  turn,  would  probably  have  resulted  in  higher 

118  Case C-223/02, Spain and Finland v Parliament and Council, ECLI:EU:C:2004:497, paragraph 29 and the case law cited there. 

23 

 
                                                 
complexity  of  the  licensing  system  and  a  higher  administrative  burden  for  the  licence  holders. 
Administrative issues may also have been faced by drivers when travelling to Member Statesthat are not 
Contracting Parties to the Vienna Convention119, for example the requirement to hold an international 
driving permit. Finally, when changing residence in the EU, holders of EU driving licences would have 
to  obtain  a  new  driving  licence  issued  by  their  new  country  of  residence,  either  by  means  of  an 
administrative exchange or by passing the driving test like any other applicant. 

Similarly, in the absence of EU action only multi- and bilateral agreements between the Member States 
could  be  applied  to  enable  mutual  recognition  of  driving  disqualifications  of  non-resident  drivers. 
However, despite the relatively broad support shown by the stakeholders for mutually recognising the 
driving disqualifications of the perpetrators of offences that are usually punishable with a disqualification 
in the EU (e.g. driving under the influence), only one such existing agreement  currently in force was 
identified120. This in turn means, that there are no driving disqualifications for committing even the most 
serious road traffic offences in other EU countries, if the decision is not taken by the Member State which 
issued the driving licence.  

In the absence of EU intervention, the integration of foreign professional drivers in the EU road transport 
sector  will  remain  limited  because  of  administrative  difficulties  for  foreign  drivers  to  maintain  their 
driving  rights.  Removing  this  barrier  could  contribute  to  solving  the  driver  shortage  issue  in  the  EU 
together with other actions, for example in relation to driver qualifications.  

4 

4  OBJECTIVES: WHAT IS TO BE ACHIEVED? 

4.1  4.1 

General objectives 

In  view  of  the  problems  identified  in  Section  2.1,  the  initiative  should  improve  road  safety  and 
facilitate the free movement of persons in the European Union. It should also contribute to sustainable 
road transport and to its digital transformation  as well as support Sustainable Development Goals 
“making cities and human settlements inclusive, safe, resilient and sustainable”121 and in particular 
“by 2030, provide access to safe, affordable, accessible and sustainable transport systems for all, 
improving road safety, notably by expanding public transport, with special attention to the needs of 
those in vulnerable situations, women, children, persons with disabilities and older persons”122. 

4.2  4.2 

Specific objectives 

The specific objectives  (SOs)  and their  correspondence with the problem  drivers  are presented in 
Figure 3. 

119  Spain, Malta, Cyprus and Ireland 
120  Agreement on the Mutual Recognition of Driving Disqualifications between Ireland and the United Kingdom of Great Britain and 
force  on  1  August  2017): 

Northern 
https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/680101/TS_24.2017_CM_954
4_WEB_UK_Ireland_Driving_Disqual.pdf  

in  Dublin  on  30  October  2015; 

(signed 

entered 

Ireland 

into 

121  Goal #11 of the UN 2030 Agenda for Sustainable Development https://sdgs.un.org/2030agenda  
122  Target 11.2 of the UN 2030 Agenda for Sustainable Development https://sdgs.un.org/2030agenda  

24 

 
                                                 
Figure 3: Correspondence between the problem drivers and the specific objectives 

SO1:  Improve  driving  skills,  knowledge  and  experience,  and  reduce  and  punish  dangerous 
behaviour. This specific objective addresses problem drivers 1 and 2. The rules on driver training, 
testing  and  probation  have  to  ensure  that  especially  young  and  novice  drivers  obtain  the  skills, 
knowledge, experience and risk awareness needed to drive safely. Also, all drivers should benefit 
from improved skills and knowledge on advanced technologies, using the safety and environmental 
potential of innovation to the full extent, as well as on ensuring a safe coexistence of motorised traffic 
and active modes. Drivers should be held accountable for their dangerous driving behaviour in all 
Member States, in order to create an environment conducive to improving road safety.  

SO2: Ensure adequate physical and mental fitness of drivers across the EU. This specific objective 
addresses  problem  driver  3.  Rules  concerning  physical  and  mental  fitness  to  drive  for 
non-professional drivers have to be improved and updated to the latest technological development. 
In addition, the medical screening process across the EU should be better aligned to contribute to the 
delivery of the road safety targets. 

SO3:  Remove  inadequate  or  unnecessary  barriers  affecting  applicants  and  holders  of  driving 
licences.  This  specific  objective  addresses  problem  drivers  4  and  5.  Notwithstanding  the  current 
levels of harmonisation, a number of barriers still persist related to drivers' access to licences and to 
the  recognition  of  their  driving  rights,  which  in  turn  hinder  freedom  of  movement  in  the  EU: 
difficulties  with  the  driving  tests  resulting  from  the  knowledge  of  languages,  different  rules  to 
determine normal residence for the residents in the EU or absence of continuity of certain driving 
rights when travelling and when changing residence in the EU. In addition, further harmonisation 
e.g.  with  regard  to  the  validity  of  the  driving  licence  and  of  mobile  driving  licences  should  be 
introduced. 

25 

PROBLEM DRIVERSSPECIFIC OBJECTIVESDrivers withinsufficientskills, knowledge, experienceand/or riskawarenessare presenton Union roadsDrivers withdangerousbehaviorare presenton Union roadsDrivers thatare not physicallyor mentallyfit to drive are presenton Union roadsApplicantsface difficultiesto obtaina drivinglicence due to inadequateor unecessaryproceduresHoldersof licences face difficultiesto have theirdrivingrightsmaintainedor recognisedin cross border contextdue to inadequateor unecessaryproceduresImprovedrivingskills, knowledgeand experience-Reduceand punishdangerousbehaviourRemoveinadequateor unecessaryproceduresaffectingapplicantsto and holdersof drivinglicencesEnsureadequatephysicaland mental fitness of drivers acrossthe EU PD1PD2PD3PD4PD5SO1SO2SO3 
 
 
5 

5  WHAT ARE THE AVAILABLE POLICY OPTIONS? 

5.1  5.1 

What is the baseline from which options are assessed? 

The EU Reference scenario 2020 (REF2020) is the starting point for the impact assessment of this 
initiative. The REF2020 takes into account the impacts of the COVID-19 pandemic on the transport 
sector. More detailed information about the preparation process, assumptions and results are included 
in the Reference scenario publication123. Building on REF2020, the baseline scenario for this impact 
assessment has been designed to include the initiatives of the ‘Fit for 55’ package proposed by the 
Commission on 14 July 2021. The baseline assumes that there is no further EU level intervention 
beyond the current Diving Licence Directive. More details on the baseline scenario are provided in 
Annex 4. The baseline scenario is common with that of the impact assessment accompanying the 
revision of the Directive (EU) 2015/413 on facilitating cross-border exchange of information on road-
safety-related traffic offences, to ensure consistency.   

The baseline also incorporates foresight megatrends124 (see section 2.3.3) and developments captured 
in the 2022 Strategic Foresight Report.125 Among others, it captures the trend of increasing demand 
for  transport  as  population  and  living  standards  grow,  the  links  between  digital  technologies  and 
greening road transport by making it more efficient, and the shift towards zero-emission vehicles, 
etc. 

The  baseline  scenario  assumes  the  achievement  of  the  milestones  of  the  Sustainable  and  Smart 
Mobility Strategy126 in terms of using more sustainable transport modes, thus reflecting in a stylised 
way other initiatives that are currently in preparation. Nevertheless, this still implies an increase in 
the road transport activity by 2030 and 2050 relative to the current levels.  

In the baseline scenario, the number of fatalities is projected to decrease by 23% by 2030 relative to 
2015 and by 30% by 2050 relative to 2015127. The number of serious and slight injuries is projected 
to decrease at a lower rate (by 18% between 2015 and 2030 and by 25% for 2015-2050). This is 
despite the increase in traffic over time. Relative to 2020, the number of fatalities and slight injuries 
is projected to decrease by 3% by 2030 while the number of serious injuries is projected to remain 
relatively  stable.  The  lower  growth  rates  in  relation  to  2020  reflect  the  impact  of  the  COVID-19 
pandemic. By 2050, the number of fatalities would be 13% lower relative to 2020 while the number 
of serious injuries would be 10% lower and that of slight injuries 11% lower. In particular, the number 
of fatalities in which novice drivers driving a car are involved are projected to increase by 3% until 
2030 (to around 3,900) and to then decrease to around 3,400 by 2050 (i.e. an overall 10% decrease 
for 2020-2050). This is because, despite the fact that novice drivers are more prone to accidents, the 
ageing of the population will lead to a decrease in the share of young drivers in the overall driver 
population. In the baseline scenario, the targets of the EU Road Safety Policy Framework 2021-2030 
– Next steps towards “Vision Zero” of reducing the number of road deaths by 50% between 2020 
and 2030 as well as reducing the number of serious injuries by 50% in the same period, would not be 
met. In addition, this is still far from the goal of the Sustainable and Smart Mobility Strategy of a 
close-to-zero death toll for all modes of transport in the EU by 2050.  

123  EU Reference Scenario 2020 | Energy (europa.eu) 
124  https://knowledge4policy.ec.europa.eu/foresight/tool/megatrends-hub_en#explore  
125  COM(2022) 289 final. 
126  EUR-Lex - 52020DC0789 - EN - EUR-Lex (europa.eu) 
127  Projections refer to injuries in which a passenger vehicle, a light commercial vehicle, a bus or a truck is  involved (power two 

wheelers are not included in the projections). 

26 

 
                                                 
The number of driving licences (A to D categories) is projected to increase by around 5% by 2030 
relative to 2019 (from around 250 million in 2019 to 263 million licences in 2030) and to remain 
relatively stable by 2050 (at around 260 million in 2050). Without further EU level action on the 
mutual recognition of mobile driving licences, the physical licences are projected to remain dominant 
in the EU by 2050. Indeed, while most of the Member States are likely to implement mobile driving 
licences, they would remain valid only on the territory of the State issuing them. To travel abroad 
within the EU, drivers would still have to keep their physical driving licences. 

In the baseline scenario, the number of theoretical and practical driving tests is projected to increase 
by 7% by 2030 (from 21.2 million in 2019 to 22.7 million in 2030) and by 12% by 2050 (at around 
23.8 million), relative to 2019. The costs associated to the theoretical and practical driving tests would 
go up from EUR 1.47 billion in 2019 to EUR 1.55 billion in 2030 and EUR 1.64 billion by 2050. 

The total number of offences committed by drivers in foreign registered vehicles is aligned with those 
used in the impact assessment supporting the revision of the CBE Directive as there should be no 
difference between the numbers of detected speeding and drink-driving offences as regards whether 
they are detected for the purposes of the CBE Directive (i.e. to issue financial penalties) or to pursue 
the cases and issue a driving ban. In the case of the impact assessment supporting the revision of the 
CBE Directive however, the relevant number of offences are the ones that are connected to remote 
detection. For the purpose of this impact assessment, all the offences which are detected are relevant, 
regardless  of the method of detection, as  long  as they  reach a level  of seriousness  that leads to  a 
driving disqualification under the law of the Member State that detected the offence. 

The number of EU exchanged licences would increase by 3% by 2030 and 4% by 2050, while the 
number of third country exchanged licences are projected to go up by 2% by 2030 and 7% by 2050. 
Without further EU level intervention, holders of foreign driving licences (including EU citizens) 
will likely continue to see their driving rights limited. Indeed, the restrictions when moving to another 
Member State will remain applicable to them. The Russian aggression of Ukraine is not expected to 
have an impact on the baseline. In particular, its possible effects in relation to driving licences have 
already been addressed and mitigated through Regulation (EU) No 2022/1280128. 

5.2  5.2 

Description of the policy options 

As  a  first  step,  a  comprehensive  list  of  possible  policy  measures  was  established  after  extensive 
consultations with stakeholders, expert meetings, independent research and the Commission’s own 
analysis.  This  list  was  subsequently  screened  based  on  the  likely  effectiveness,  efficiency  and 
proportionality of the proposed measures in relation to the given objectives, as well as their legal, 
political and technical feasibility. 

5.2.1  Discarded policy measures 

Not taking action has been discarded, considering the need to adapt the current rules to technological, 
societal and scientific developments. Among others, the current framework on driving licences does 
not allow for accommodating mobile driving licences. Consequently, it is becoming a barrier to the 
digital  transformation,  including  the  significant  benefits  it  can  bring  in  terms  of  cost  savings  and 
simplification. Several possible policy measures were also considered during the impact assessment 
process but were discarded because proposing an action to address the issue at EU level would not 

128  OJ L 195, 22.7.2022, p. 13. 

27 

 
                                                 
yield  additional  results.  Further  details  on  the  discarded  policy  measures  and  the  reasons  for 
discarding them are set out in Annex 5.  

5.2.2  Retained policy measures 

The retained policy measures have been grouped in 3 policy options: policy option A (PO-A), policy 
option B (PO-B)  and  policy option  C  (PO-C).  Table 1Table 1 presents the list of policy measures 
included  in  the  policy  options  with  the  problem  drivers  and  specific  objectives.  A  more  detailed 
description of the policy measures is included in Annex 6. 

All three policy options include 12 common policy measures (“PMc”) that are presented in Table 1. 
These  policy  measures  reflect  the  necessary  changes  due  to  technological,  scientific  and  societal 
evolutions in the EU and will be included in each policy option.  

Table 1: Overview of policy measures common to the three options 

Policy measure 

PMc 1: Update of standards on skills and knowledge to be met for the first issuance of a 
driving licence. 

PMc 2: Introduction of rules to remove restrictions associated to automatic gear transmission.  

PMc 3: Amendments to the definitions of vehicle categories for cars and vans (maximum 
mass) 

PMc 4: Improvement of RESPER for the purpose of enforcement  

PMc  5:  Update  of  standards on  physical  and  mental  fitness  to  be  met  for  the  issuance  of 
driving licences 

PD3 

PMc 6: New rules on the use of technologies to mitigate medical unfitness  

PMc  7:  Establishment  of  a  knowledge  management  platform  for  authorities  regarding 
physical and mental fitness to drive 

PMc 8: Clarification of the concept of normal residence 

PMc 9: Introduction of an EU mobile driving licence  

PMc 10: Introduction of a possible QR code on the physical licence in the areas reserved for 
microchip 

PMc 11: Improvement and simplification of rules on administrative validity. 

PMc 12: Mutual recognition of optional equivalences – New equivalence applicable to small 
bus combined with a trailer  

PD4 
PD5 

PD5 

Problem 
Driver 

PD1 

Specific 
objective 

SO1 

PD2, PD4 
PD5 

SO1 
SO3 

SO2 

SO3 

Table 2 includes the additional policy measures for PO-B (7) and PO-C (13). These policy options 
represent an additional level of ambition and scope, as explained below. 

Table 2: Overview of policy measures not common to the three options 

Policy measure 

Problem 
Driver 

Specific 
objective 

Option B 

Option C 

PM  1:  Rules  on  training  and  probation  periods  - 
Recommendation on lifelong training  

PM  2:  Amendments  to  the  definition  of  the  mopeds’ 
category to include certain micro mobility means 

PM  3:  Introduction  of  a  new  category  for  tractors  - 
amendment to the definition of the small bus category  

PD1 
PD2 

PD1 

SO1 

SO1 

X 

PM 4: Mutual recognition of driving disqualifications  

PD2 

SO1 

X 

X 

X 

X 

28 

 
 
 
 
 
 
 
Policy measure 

Problem 
Driver 

Specific 
objective 

Option B 

Option C 

SO2 

SO3 

PM  5:  Rules  on  consequences  of  penalty  points  for  non-
residents  -  Rules  on  rehabilitation  in  case  of  a  change  of 
normal residence  

PM 6: Rules on simple medical screening  

PM 7: Rules on advanced medical screening  

PM  8:  Removal  of  the  staging  requirement  to  obtain  a 
licence of category CE or DE  

PM 9: Flexibility for the first issuance of driving licences 
in case of restrictions related to languages  

PM  10:  Mutual  recognition  of  physical  and  mental 
assessment  

PM 11: New optional equivalence related to vehicles with 
limited maximum speed  

PM 12: Rules on the removal of code 70 

PM  13:  New  optional  equivalence  related  to  bus  without 
passengers 

PM 14: Rules on the exchange of foreign driving licences.  

PD3 

PD4 

PD4 
PD5 

PD5 

5.2.3  Description of the options 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

Three policy options (PO-A, PO-B and PO-C) have been designed to  address all problem drivers 
identified in relation to road safety and to the free movement of persons. All options contribute to the 
general objectives by removing obstacles for applicants and for holders of driving licences, and by 
reducing the number of road traffic accidents.  

PO-A  reflects  the  basic  update  of  the  Directive,  taking  into  account  the  lessons  learnt  from  the 
evaluation and integrating societal, technological  and scientific evolutions. It does not  change the 
scope of the Directive and it contains measures which are also included in PO-B and PO-C. 

PO-B includes additional efforts to meet EU road safety objectives, targeting all drivers (including 
novice  drivers)  in  three  important  domains:  skills  and  knowledge,  medical  fitness  and  dangerous 
behaviour. It also removes some barriers on the free movement of persons faced by holders of foreign 
licences and applicants. 

Finally, PO-C reinforces the road safety measures introduced with PO-B regarding medical fitness 
and  dangerous  behaviour.  It  also  extends  the  scope  of  the  Directive  to  new  vehicles  (tractors,  e-
scooters with a maximum speed of 25 km/hour). 

Policy option A 

Policy option A (PO-A) includes policy measures that are common to all three policy options. The 
measures under PO-A aim at aligning the Directive on driving licences to the technological, scientific 
and societal developments in the EU. While the current  scope of the Directive  remains the same, 
improvements are brought to its main provisions answering to the market needs and opportunities.  

PO-A  will  contribute  to  road  safety.  To  address  Specific  Objective  1  “Improve  driving  skills, 
knowledge and experience and reduce and punish dangerous behaviour”, the range of issues subject 
to testing will be extended, in particular to check drivers’ knowledge of new vehicle features and to 
introduce hazard perception tests (PMc1).  

29 

 
 
 
 
 
 
 
 
In  addition,  improvements  to  RESPER  (the  network  for  the  exchange  of  information  related  to 
driving licences) will support further cooperation between issuing authorities, in particular in relation 
to law enforcement, and thereby better fight against fraud and dangerous behaviour (PMc4). For that 
purpose, requirements on the response time and data quality of RESPER will be introduced and the 
use cases will be better specified in order to avoid legal uncertainty. It will result in a system relevant 
to support the control of driving licences.  

PO-A  will  also  ensure  adequate  levels  of  skills  and  knowledge  to  accompany  the  uptake  of 
zero-emission vehicles. Today’s driving licence rules reflect the fact that the EU vehicle fleet still 
uses predominantly conventional fuels. The rules will be updated to take into account the increased 
uptake of alternatively fuelled vehicles with automatic gear transmission (PMc2) and the excess of 
mass resulting from electric vehicles’ propulsion systems (PMc3). 

In addition, to support Specific Objective 2 “Ensure adequate physical and mental fitness of drivers 
across the EU”, the standards on physical and mental fitness to be met by applicants (PMc5) and the 
rules on the use of technologies to mitigate unfitness to drive (PMc6) will be updated in line with 
technological  and  scientific  developments129.  Also,  a  new  dedicated  information  platform  will  be 
established  to  allow  for  wider  sharing  of  information  and  to  improve  knowledge  management 
between authorities by means of annual meetings (PMc7). 

Furthermore,  to  support  specific  objective  3  “Remove  inadequate  or  unnecessary  barriers  affecting 
applicants and holders of driving licences”, the same administrative validity of driving licences for category 
A and B (non-professional) should be applied in all MS. The issue of validity periods for licences is resulting 
from the possibility for Member States to select two durations (10 or 15 years). When a person changes 
normal residence and asks for an exchange of driving licences, the administrative validity of his or her 
driving rights may be reduced. This poses a problem for the free movement of people by setting unnecessary 
administrative barriers to the holders of EU driving licences, and the objective here is to remove the barriers 
related to the recognition of their rights (SO3). Measure PMc11 (Improvement and simplification of rules 
on administrative validity) will simplify the procedure for the citizens currently holding a driving licence of 
10 years’ administrative validity. Lessons learned from the COVID-19 pandemic will also be considered 
and authorities could waive requirements on administrative validity in exceptional circumstances. Optional 
equivalences130 will be mutually recognised (PMc12). Specific implementing rules will be introduced to 
develop the concept of normal residence which will specify how the normal residence should be determined 
during the six first months of establishment in a new country, including special cases where two or more 
Member States consider they can be issuing authority. (PMc8), in particular to avoid that a person is not 
able to have his or her normal residence determined. Additional equivalence will be introduced allowing 
the holder of a licence of category D1 and CE to drive a small bus with a trailer (PMc12). 

Finally, the free movement of persons will be ensured also in the digital era, through the introduction of the 
EU mobile driving licence (PMc9). In parallel, it will be possible to add a QR code on physical driving 
licences to improve security of documents. It will allow administrations, law enforcement and potentially 
private  bodies  to  verify  the  authenticity  of  the  information  printed  on  the  driving  licences  (similar 
mechanisms as for the EU covid certificate). It will also reduce costs compared to the chipset currently 
foreseen under the existing Driving Licence Directive (PMc10).  

Policy option B 

129  For example alcohol interlocks in case of dependence to alcohol or potentially in the future certain ADAS technologies to offset 

the consequences of Mild Cognitive Impairments.  

130  For example, if a person is authorised to drive a light motorcycle with a licence of category B in his or her country of residence, 

he or she will be able to do the same in any other MS that has applied the same optional equivalence 

30 

 
                                                 
Policy option B (PO-B) represents an increase of policy intervention as regards road safety, as well 
as the reduction of administrative burden affecting professional drivers, holders of foreign driving 
licences, EU citizens not fluent in the language of their state of residence and young persons in remote 
areas. 

Regarding Specific Objective 1 “Improve driving skills, knowledge and experience and reduce and 
punish dangerous behaviour”, besides the measures included in PO-A, new rules on training and 
probation periods will ensure that novice drivers are better prepared for driving safely in complex 
traffic situation. Lifelong training will be promoted to keep the skills of experienced drivers up to 
date, also in the advent of new technologies (PM1). Moreover, road safety is expected to be further 
improved  also  by  introducing  the  mutual  recognition  of  driving  disqualifications  for  major  road 
safety-related offences (such as driving under the influence of alcohol) (PM4).  

Regarding Specific Objective 2 “Ensure adequate physical and mental fitness of drivers across the 
EU”, in addition to the updated standards on physical and mental fitness to be met by applicants and 
drivers introduced under PO-A, a simple fitness screening based on a self-assessment will become 
mandatory at first issuance and at renewal together with the possibility for more frequent screening 
of drivers’ medical fitness for drivers above 70 years old. A training programme to support general 
practitioners will be set up to support the introduction of these new screening rules (PM6).  

In relation to Specific Objective 3 “Remove inadequate or unnecessary barriers affecting applicants 
and holders of driving licences”, in addition to the measures under PO-A, the issuance of the driving 
licence document will be simplified.  

Applicants who are EU nationals will be able to obtain their first driving licence of category B either 
in their country of residence or in their country of citizenship in the event their country of normal 
residence does not allow interpreters and their native language is not available for test there (PM9). 
This will be possible due to the adaptation of the rules on normal residence and it will address the 
problems  faced  by  persons  not  sufficiently  at  ease  with  the  official  languages  of  their  country  of 
residence. This measure has been designed by considering the risk of fraud (driving licence tourism). 
It  is  therefore limited to  cases where the set-up  related to  test  languages can be problematic, and 
limited to category B licences.  

To mitigate the shortage of professional drivers, existing rules on bus and truck drivers  would be 
simplified, to enable more flexibility between these professions (PM8). The measure will remove the 
requirement to hold a driving licence of category C (truck) or D (bus) to obtain a driving licence of 
category CE or DE (same vehicles but with a trailer) (PM8).   

Rules on the exchange of driving licences issued by third countries applying licensing schemes of 
similar performance as the EU will be introduced (PM14). They will allow holders of driving licences 
issued by the third country whose licensing system guarantees a level of road safety equivalent to the 
one in the EU to obtain an EU driving licence by means of an administrative exchange. The driving 
licences issued in that context will not be marked with the harmonised Union code 70. This right will 
be also be provided to holders of licences issued by third countries who have previously obtained a 
driving licence following a test in the EU (e.g. an expatriate returning to the EU). In addition, Member 
States  will  keep  the  bilateral  competence  to  determine  other  third  countries  with  which  an 
administrative exchange is possible, as it is the case now. 

Finally, to cater for mobility issues in remote areas, it will be possible for Member States to extend driving 
rights of the holder of a B1 driving licence by allowing them to drive vehicles of a higher mass with a 
maximum speed up to 45 km/h, but only on the national territory of the relevant Member States (PM11).  

31 

 
Policy option C 

Policy option C (PO-C) represents a further increase in harmonisation and scope compared to option 
PO-B,  notably  by  introducing  rules  on  the  recognition  of  penalty  points  for  non-residents,  by 
requiring a driving licence for micro mobility vehicles with a speed beyond 25 km/h and by laying 
down rules on the mutual recognition of a physical and mental fitness assessment.  

On Specific Objective 1 “Improve driving skills, knowledge and experience and reduce and punish 
dangerous  behaviour”,  the  mutual  recognition  of  driving  disqualifications  will  be  reinforced  and 
complemented  by  rules  on  penalty  points’  systems  and  rehabilitation  (PM5).  Furthermore,  the 
categories of vehicles for which a driving licence is required would be amended to include new smart 
mobility vehicles of a maximum speed between 25 and 45 km/h (PM2). This issue is mainly related 
to problem driver 1 (insufficient skills, knowledge, experience and/or risk awareness) and it is due to 
an increasing use of e-scooters and other forms of micro-mobility in cities, resulting in an increase 
of accidents affecting their users. Stakeholders’ consultations and desk research131 have underlined 
that users of these vehicles are exposed to similar risks as other vulnerable road users (i.e. cyclists 
and moped riders). It has also been noted that the risk profile of certain micro mobility means can be 
very similar to the one of mopeds, especially when the design speed is between 25 and 45 km/hour. 
Consequently, the drivers of these vehicles will be subject to tests similar to the ones for mopeds 
(category AM), ensuring a minimum level of driving skills and knowledge of the road traffic rules. 
Finally, the mutual  recognition  of national  licences  required to drive  agricultural  vehicles will be 
introduced to solve problems faced by cross-border farming activities, and the definition of category 
D1 (for small buses) will be updated (PM 3) by increasing the number of authorised passengers from 
16  to  22  in  order  to  better  align  it  with  the  market  opportunities  and  needs.  Regarding  tractors, 
licences for agricultural or forestry tractors are governed at national level. Consequently, there is no 
mutual recognition resulting in obstacles affecting notably posted workers, agricultural contractors 
and  cross-border  agricultural  activities.  Regarding  small  buses,  the  definition  of  the  category  D1 
includes buses of a maximum length of 8 meters with 9 to 16 passenger seats. The ex-post evaluation 
has identified that  the  current  market  supply provides for buses of such  dimension with  up to  22 
passenger seats.  

Regarding Specific Objective 2 “Ensure adequate physical and mental fitness of drivers across the 
EU”,  option  PO-C  requires  that  the  mandatory  screening  of  medical  fitness  at  first  issuance  or 
renewal be carried out by a general practitioner and it foresees more frequent screening of drivers’ 
medical  fitness  from  the  age  of  65  years  and  onwards.  A  training  programme  to  support  general 
practitioners will be set up to support the introduction of these new screening rules (PM7).  

In relation to Specific Objective 3 “Remove inadequate or unnecessary barriers affecting applicants and 
holders of driving licences”, in addition to the measures under policy option B, the mutual recognition of 
physical and mental fitness assessment (PM 10) will be introduced as a consequence of the harmonised 
medical screening. In addition, former holders of driving licences issued by a third country should be able 
to continue to drive when changing their residence to another Member State, provided they have a positive 
road safety track record of at least 5 years (PM12). For that purpose, the initiative will specify that the 
restrictions associated to code 70 will not apply once these conditions are met.  

Finally, rules relevant to professional drivers will be further simplified, allowing MS to authorise the 
holder of a driving licence of category C (truck) to drive a bus without passengers on their territory. 
This will mainly affect employees in charge of maintenance and the repair of buses and trucks and 

131  https://www.itf-oecd.org/sites/default/files/docs/safe-micromobility_1.pdf 

32 

 
                                                 
with the measure, the workers will not have to obtain the licences for both trucks (category C) and 
buses (category D) (PM13).   

All  policy  options  fully  encompass  the  ‘digital  by  default’  principle,  reflecting  the  2030  Digital 
Compass Communication.132  They  enable smooth  digital  policy implementation and foster digital 
transformation,  as  they  have  been  designed  with  digitalisation  as  the  first-best  option,  where 
available. For example, mobile driving licences have the end user at the centre of digitalisation, will 
be issued by default from 2028 and will be interlinked with the EU Digital Identity Wallet,133 the use 
of  RESPER  ensures  interconnectivity  for  MS  authorities,  while  training  and  testing  of  drivers’ 
knowledge of ADAS systems levers digital and technological innovation to improve road safety. 

5.2.4  Main trade-offs 

To identify the measures which may require trade-offs between the objectives, measures with a likely 
negative impact on road safety while having positive impact on green transition, free movement of 
persons  and  administrative  simplification,  have  been  considered.  Multiple  consultation  activities 
have been conducted to confirm for each of these measures the problem driver they would address 
and to identify potential mitigation actions, in particular when similar provisions exist at national 
level.  

When no mitigation action was available to control the negative impact on road safety, or when the 
risk of negative impacts on road safety was considered too high, the measures have been discarded. 
This applies for example to measures such as reducing the minimum age required for obtaining a 
driving licence, removal of the graduated access scheme for category A licences and removal of code 
70 (see also Annex 5 on discarded measures). 

The analysis of the main trade-offs has been performed for the cases discussed below: regarding the 
rules  on  driving  vehicles  with  automatic  gear  transmission,  increase  of  vehicles’  mass  due  to  the 
transition  to  alternative fuels,  optional  equivalence in  case of vehicles with limited speed and the 
minimum age requirement to drive.  

Regarding the rules applicable to vehicles with automatic gear transmission, and related possible 
trade-offs between green transition and road safety, it should first be underlined that the skills and 
knowledge required to drive cover both the control of the vehicle and behaviour in traffic. This is 
reflected in the skills to be assessed during the driving test, as specified in Annex II to the Directive. 
During the consultation activities and in particular the first workshop, it has been underlined that the 
easiness to operate vehicles with automatic transmission allows for better results regarding behaviour 
in traffic of novice drivers having passed the test with automatic gear transmission.  

Measure  PMc  2  (Introduction  of  rules  to  remove  restrictions  associated  to  automatic  gear 
transmission)  has  been  designed  in  a  way  to  avoid  negative  effects  on  road  safety.  Therefore,  an 
additional certified training or a short practical test would be required to remove the restrictions on 
drivers having passed the test on a vehicle with automatic gear transmission (licences marked with 
code 78). It will focus on the skills and knowledge specific to manual gear transmission. A similar 
scheme  is  already  in  place  in  Germany  with  an  effect  limited  to  its  national  territory,  and  the 
competent authority has not reported specific road safety issues with its implementation. 

132  Commission Communication, 2030 Digital Compass: the European way for the Digital Decade, COM(2021) 118. 
133  Regulation  of  the  European  Parliament  and  of  the  Council  amending  Regulation  (EU)  No  910/2014  as  regards  establishing  a 

framework for a European Digital Identity. 

33 

 
                                                 
Regarding  the  increase  of  vehicles’  mass  resulting from  the  shift  to  alternative  fuels,  and  the 
related  possible  trade-off  between  green  transition  and  road  safety,  category  B  driving  licences 
includes  vehicles  with  a  maximum  mass  up  to  3.5  tons,  according  to  the  Directive.  Battery 
technologies have significantly evolved during the last years. The weight of electric cars remains now 
on average below 2 tons134. Consequently, vans are the vehicles for which the shift to  alternative 
fuels would require a higher category of driving licences. The total number of vans in the EU was 
about 29 million in 2020, while the alternatively fuelled vans accounted for only 1.9% of all vans on 
the road135. In addition, new vehicles are required by the General Safety Regulation136 to be equipped 
with  advanced  safety  technologies  (such  as  advanced  driving  assistance  systems),  which  will 
significantly improve road safety137.  

The increase of the maximum mass for category B to 4.25t (PMc 3) is therefore expected to have a 
very limited negative impact on road safety, mainly because of a higher risk for other vulnerable road 
users compared to lighter vehicles. Indeed, the expected negative effect resulting from a higher mass 
will  be  largely  mitigated  by  the  scope  of  application  of  the  measure  (only  alternatively  fuelled 
vehicles) and the fact that almost all the vehicles concerned will benefit from advanced technologies 
regarding road safety. 

Regarding  the  minimum  age  requirements  to  drive,  and  related  possible  trade-offs  between 
simplification and road safety, two measures are likely to increase the presence of young drivers on 
the road: 

  With the introduction of rules on accompanied driving (PM 1), applicants to licences of category B and 
C will have the possibility to pass the driving test at 17 years of age. However, they will not be authorised 
to drive alone before 18 years of age. Such a system is already available for category B in some Member 
States  (e.g.  Germany,  Austria)  and  has  shown  very  positive  effects  on  road  safety.  The  learner  is 
acquiring experience under the supervision of an adult and is more capable to drive when he/she reaches 
18 years of age. The effect on road safety for this measure is expected to be positive.  

  The optional possibility to allow driving vehicles with maximum speed and mass limitations with 
a licence of category B1 instead of category B (PM 11) is expected to improve the mobility of 
young  people,  especially  in  rural  areas.  The  measure  may  pose  an  additional  road  safety  risk, 
notably for vulnerable road users. However, the measure is proposed to be optional (it requires a 
decision of the concerned Member State), the maximum speed and the mass of the vehicles are 
significantly limited (45 km/hour and 2.5 tons) in order to reduce the consequences of an accident, 
and  the  category  of  concerned  drivers  is  narrowed  down  to  the  strict  need  (applicable  only  to 
drivers aged up to 21 years). Finally, the requirements on skills and knowledge to be met at the 
driving test for a licence of category B1 are the same as for category B but for a lower speed (60 
km/hour138). 

6 

6  WHAT IS THE IMPACT OF THE POLICY OPTIONS? 

This  section  summarises  the  main  expected  economic,  social  and  environmental  impacts  of  each 
policy  option139.  The  proposed  measures  included  in  the  policy  options  are  assumed  to  be 

134  https://www.eea.europa.eu/ims/new-registrations-of-electric-vehicles 
135  vans_fact_sheet_ACEA.pdf 
136  Regulation (EU) 2019/2144 (OJ L 325, 16.12.2019, p. 1). 
137  https://ec.europa.eu/commission/presscorner/detail/en/IP_22_4312  
138  The two values of speed (45 and 60km/hour) are different because category B1 is targeting heavy quadri- motorcycles which are 

usually lighter than these vehicles (modified M1 category). 

139  The analysis in this section is based on COWI et al. (2022), Impact assessment support study for the revision of the directive on 

driving licences, and on the analysis of stakeholders' feedback. 

34 

 
                                                 
implemented  from  2025  onwards,  so  that  the  assessment  has  been  undertaken  for  the  2025-2050 
period, and it refers to EU27. Costs and benefits are expressed as present value over the 2025-2050 
period, using a 3% discount rate. As the analysis covers a long-term future, it incorporates foresight 
analysis described in section 2.3.3 and in the baseline section. Further details on the methodological 
approach are provided in Annex 4. 

6.1  6.1 

Economic impact 

The assessment of the economic impacts includes the costs which the various policy options entail for public 
administrations, the private sector and citizens. In addition, this section covers the impacts on SMEs, 
digital by default140 and the functioning of the internal market and competition.  

6.1.1 

Impact on public administrations 

Adjustment  costs  for  Member  States  administrations.  The  adjustment  costs  for  Member  States 
administrations  are  the  same  in  PO-A,  PO-B  and  PO-C,  driven  by  three  policy  measures  (PMc1, 
PMc4 and PMc9) included in all options. More specifically, the update of standards on skills and 
knowledge for the first issuance of a driving licence (PMc1) requires the development of (animated) 
videos for the driver hazard perception test (HPT). These videos are assumed to be developed and 
updated  every  5  years,  starting  from  2025.  At  EU  level,  the  costs  for  implementing  PMc1  are 
estimated at EUR 3.5 million in 2030 and 2050 relative to the baseline (see Table 3)141. In addition, 
the improvement of RESPER for the purpose of enforcement (PMc4) is estimated to lead to one-off 
costs of EUR 50,000 on average per Member State, i.e. EUR 1.4 million for the whole EU in 2025. 
Furthermore, the introduction of the EU mobile driving licence (PMc9) requires the development of 
an IT system for mobile driving licences142. Such an IT system would involve one-off costs of EUR 
12.9  million  in  2025  plus  annual  maintenance  costs  estimated  at  EUR  1.9  million  relative  to  the 
baseline (see Table 3). The other measures included in the three options do not have a significant 
impact on the adjustment costs for Member States administrations. The detailed impacts on costs by 
policy measure are provided in Annex 4.  

Overall, PO-A, PO-B and PO-C are estimated to result in one-off adjustment costs for EU Member 
States’ administrations of EUR 14.3 million in 2025 and to recurrent adjustment costs of EUR 5.5 
million in 2030 and 2050 relative to the baseline (see Table 3). Expressed as present value over the 
2025-2050 horizon (in 2021 prices), the total adjustment costs for the Member States administrations 
(including one-off costs) are estimated at EUR 63.2 million in all policy options.  

Table 3. Recurrent costs and costs savings for Member States administrations in the POs relative to the baseline 
scenario (EU27), in million EUR (2021 prices)143  

Adjustment costs - recurrent 

PMc1 – updated standards on skills 
PMc4 – improvement of RESPER 
PMc9 – EU mobile driving licence 

Enforcement costs  

PO-A 

Difference to the baseline 
PO-B 

PO-C 

2030 

2050 

2030 

2050 

2030 

2050 

5.5 
3.5 

1.9 
0.0 

5.5 
3.5 

1.9 
0.0 

5.5 
3.5 

1.9 
1.5 

5.5 
3.5 

1.9 
1.1 

5.5 
3.5 

1.9 
4.5 

5.5 
3.5 

1.9 
3.0 

140  https://ec.europa.eu/info/sites/default/files/file_import/digitally-transformed_user-focused_data-driven_commission_en.pdf  
141  Belgium, Germany, Finland and the Netherlands already implement this measure and thus no additional costs are expected for 

these Member States relative to the baseline.  

142  Different costs are foreseen for the Member States that would need to set up the system and those that have a system in place or 

under development but would need to upgrade it. More details are provided in Annex 4. 

143  Source: COWI, Ecorys and NTUA (2022), Impact assessment support study; Note: excluding one-off adjustment costs 

35 

 
  
  
  
  
  
  
  
                                                 
PM4 – driving disqualifications (I) 
PM5 – driving disqualifications (II) 

Enforcement cost savings  

PMc9 – EU mobile driving licence 
PMc10 – QR code 
PMc11 – administrative validity 

Administrative cost savings  

PMc9 – EU mobile driving licence 

1.5 

1.1    

145.9 
129.0 
0.03 
16.9 
90.8 
90.8 

181.2 
145.5 
0.04 
35.7 
133.2 
133.2 

145.9 
129.0 
0.03 
16.9 
90.8 
90.8 

181.2 
145.5 
0.04 
35.7 
133.2 
133.2 

4.5 
145.9 
129.0 
0.03 
16.9 
90.8 
90.8 

3.0 
181.2 
145.5 
0.04 
35.7 
133.2 
133.2 

Enforcement  costs  for  Member  States  administrations.  In  PO-B  the  driving  disqualifications 
resulting  from  specific  offenses  (for  example  driving  under  the  influence  of  alcohol)  would  be 
mutually recognised (PM4). The increase in the number of driving disqualifications for such offences 
is estimated at 182,514 in 2030 and 225,000 in 2050 relative to the baseline. Total enforcement costs 
for Member States authorities are estimated at EUR 1.5 million in 2030 and EUR 1.1 million in 2050 
relative to the baseline (see Table 3). These costs are related to the time required for investigations144 
and mailing costs. More details on the estimation of the costs are provided in Annex 4, including 
detailed results by Member State.  

In PO-C, penalty points will also be applied to non-residents and driving disqualification resulting 
from penalty points system should be mutually recognised (PM5). The total number of cases where 
the penalty points need to be applied is estimated at 525,288 in 2030 and 606,915 in 2050 relative to 
the baseline. Total enforcement costs for Member States authorities are estimated at EUR 4.5 million 
in 2030 and EUR 3 million in 2050 relative to the baseline (see Table 3). Expressed as present value 
over  the  2025-2050  horizon  (in  2021  prices),  the  enforcement  costs  for  Member  States 
administrations are estimated at EUR 26.3 million in PO-B and EUR 75.3 million in PO-C.  

Enforcement  cost  savings  for  Member  States  administrations.  The  three  policy  options  entail 
enforcement cost savings for the Member States administrations. They are driven by three common 
policy measures (PMc9, PMc10 and PMc11) included in PO-A, PO-B and PO-C and are thus the 
same for all options. More specifically, the introduction of the EU mobile driving licences (PMc9) is 
expected to lead to cost savings related to the production of driving licences, estimated at EUR 129 
million in 2030 and EUR 145.5 million in 2050 relative to the baseline (see Table 3). The enforcement 
cost savings due to the introduction of a QR code on the physical licence in the areas reserved for a 
microchip (PMc10) are estimated to be limited (EUR 0.03 million in 2030 and 0.04 million in 2050) 
relative to the baseline. This is because only the Netherlands makes use of microchips (and would 
thus  be affected by PMc10) and most driving licences would  become digital  in  PO-A, PO-B and 
PO-C  as  an  effect  of  PMc9.  In  addition,  PMc11  (improvement  and  simplification  of  rules  on 
administrative validity) is estimated to lead to enforcement cost savings of EUR 16.9 million in 2030 
and EUR 35.7 million in 2050 relative to the baseline (see Table 3). This is because, in PMc11, the 
15  year  long  administrative  validity  of  driving  licences  for  A  and  B  categories  will  be  made 
mandatory and exclusive. The Directive currently requires an administrative validity period of 10 

144  Based on stakeholders’ consultation in the context of the impact assessment for the revision of Directive (EU) 2015/413 facilitating cross-
border exchange of information on road-safety-related traffic offences (CBE Directive), the investigation time per foreign registered offence 
is currently around 15 minutes. The time spent on investigation depends to a large extent on whether the process is automated or not. Member 
States that adopt an automated system, and adopt an owner/holder liability regime, generally have an investigation time between 1 and 3 
minutes. In the baseline scenario, a decrease in the investigation time of 5% per year has been assumed, in line with the impact assessment 
accompanying the revision of the CBE Directive. The investigation time is thereby estimated at 15 minutes in 2019, 8.5 minutes in 2030, 5.1 
minutes in 2040 and 3.1 minutes in 2050. This explains why the enforcement costs decrease over time relative to the baseline, while the 
number of investigations increases.  

36 

 
  
  
  
  
  
  
  
 
                                                 
years but allows Member States to also issue licences for 15 years. Thus, PMc11 would only lead to 
cost savings for the 15 Member States that issue licences with an administrative validity period of 10 
years145. The detailed impacts on costs by policy measure are provided in Annex 4, also accounting 
for the synergies between the measures included in each option. 

Overall, PO-A, PO-B and PO-C are estimated to result in enforcement cost savings for EU Member 
States administrations of EUR 145.9 million in 2030 and EUR 181.2 million in 2050 relative to the 
baseline (see Table 3). Expressed as present value over the 2025-2050 horizon (in 2021 prices), the 
total enforcement cost savings for the Member States administrations are estimated at EUR 2,830.6 
million in all policy options.  

Administrative  cost  savings  for  Member  States  administrations.  For  all  policy  options,  the 
introduction of the EU mobile driving licence (PMc9) is also expected to lead to administrative cost 
savings for Member States administrations estimated at EUR 90.8 million in 2030 and EUR 133.2 
million in 2050 relative to the baseline (see Table 3). Expressed as present value over the 2025-2050 
horizon (in 2021 prices), the total administrative cost savings for the Member States administrations 
are estimated at EUR 1,969.3 million in PO-A, PO-B and PO-C. These costs are related to the time 
spent to ensure that the physical licences are issued to the right person, and thus the time spent to 
validate the identity of the person to which a new licence is provided. When procedures are digitised, 
the  time  spent  on  such  procedures  and  the  associated  costs  are  overcome.  The  other  measures 
included  in  the  three  options  do  not  have  a  significant  impact  on  the  administrative  costs  or  cost 
savings  for  Member  States  administrations.  The  detailed  impacts  on  costs  savings  for  PMc9  are 
provided in Annex 4. 

Net cost savings for Member States administrations. Overall, when considering the adjustment costs 
(both  one-off  and  recurrent),  the  enforcement  costs,  the  enforcement  cost  savings  and  the 
administrative cost savings, the net cost savings for Member States administrations are estimated at 
EUR 4,736.6 million in PO-A, EUR 4,710.4 million in PO-B and 4661.4 million in PO-C, expressed 
as present value over the 2025-2050 horizon (in 2021 prices) relative to the baseline. The net cost 
savings for Member States administrations are largely driven by the introduction of the EU mobile 
driving licences (PMc9). The difference between net savings between policy options is explained by 
PM4 and PM5 which are included only in PO-B and PO-C, respectively.  

Adjustment costs for the European Commission. Three policy measures included in the options are 
expected to lead to adjustment costs for the European Commission: PMc7 (common to PO-A, PO-B 
and  PO-C),  PM6  (included  in  PO-B)  and  PM7  (included  in  PO-C).  The  costs  for  the  European 
Commission of PO-B (due to PM6) and PO-C (due to PM7) are expected to be the same.  

PMc7  (establishment  of  an  information  platform  for  authorities  to  exchange  on  the  physical  and 
mental fitness to drive) would involve the organisation by the Commission of one meeting per year 
between national experts, to exchange knowledge and best practices regarding physical and mental 
fitness to drive, complemented by other online events. The cost of the meeting is estimated at EUR 
30,000  per  year  (from  2025  onwards)  and  includes  the  reimbursement  of  the  national  experts.  In 
addition,  both  PM6  (rules  on  simple  medical  screening)  and  PM7  (rules  on  advanced  medical 
screening)  would  require  the  development  of  an  (online)  training  programme  for  general 
practitioners. The costs for developing the online content of the training programme are estimated at 
EUR 33,500 to EUR 142,000, depending on the level of detail. The training programme is assumed 

145  These Member States are: BE, BG, EE, ES, HR, HU, IE, IT, LT, LV, MT, NL, RO, SE and SI.  

37 

 
                                                 
to be updated regularly (once every five years), starting from 2025. More detailed explanations are 
provided in Annex 4.   

Overall, PO-A is estimated to result in adjustment costs for the European Commission of EUR 0.03 
million in 2030 and 2050 relative to the baseline, while PO-B and PO-C would lead to costs of EUR 
0.06 to 0.17 million in 2030 and 2050 relative to the baseline. Expressed as present value over the 
2025-2050  horizon  (in  2021  prices),  the  total  adjustment  costs  for  the  European  Commission  are 
estimated at EUR 0.6 million in PO-A, and at EUR 0.7 to 1.1 million in PO-B and PO-C.  

6.1.2 

Impact on the private sector  

Hassle costs savings  for road  transport  operators. PMc9 (introduction of the EU mobile driving 
licences), included in all three policy options, is estimated to lead to a reduction in hassle costs for 
the renewal of category C and D licences146. A World Bank study147 on the Estonian e-Government 
system conservatively estimated that each renewal request saved 15 minutes on average compared to 
the case where the system was not in place. C and D licences are mainly used by professional drivers 
and  the  cost  savings  are  thus  expected  to  benefit  transport  operators,  mainly  SMEs  in  the  road 
transport sector (SMEs represent 99% of the road transport operators)148. The hassle cost savings are 
derived by using the average labour costs by Member State149, and are estimated at EUR 32.8 million 
in 2030 and EUR 38.7 million in 2050 relative to the baseline (see Table 4)150. Expressed as present 
value  over  the  2025-2050  horizon  (in  2021  prices),  total  hassle  cost  savings  for  road  transport 
operators are estimated at EUR 587 million in PO-A, PO-B and PO-C relative to the baseline. 

Adjustment costs for general practitioners. In PO-B, the measure related to rules on simple medical 
screening  (PM6)  is  expected  to  lead  to  4,515  additional  (online)  training  courses  for  general 
practitioners in 2030 and 5,057 courses in 2050, relative to the baseline151. The adjustment costs for 
general practitioners in PO-B are estimated at EUR 3.1 million in 2030 and EUR 3.4 million in 2050 
relative to the baseline152 (see Table 4). In PO-C the measure related to rules on advanced medical 
screening  (PM7)  has  the  same  impact  as  PM6  in  terms  of  costs  for  (online)  training  courses  for 
general practitioners. Expressed as present value over the 2025-2050 horizon (in 2021 prices), total 
adjustment costs for GPs are estimated at EUR 57.7 million in PO-B and PO-C. 

Table 4: Costs and cost savings for the private sector in the POs relative to the baseline scenario (EU27), in million 
EUR (2021 prices)153 

PO-A 

Difference to the baseline 
PO-B 

PO-C 

2030 

2050 

2030 

2050 

2030 

2050 

Hassle cost savings  

PMc9 – EU mobile driving licence 

32.8 
32.8 

38.7 
38.7 

Adjustment costs  

PM6 – simple medical screening 

32.8 
32.8 

3.1 
3.1 

38.7 
38.7 

3.4 
3.4    

32.8 
32.8 

3.1 

38.7 
38.7 

3.4 

146  These costs relate for example to the waiting time for picking up the physical licence, etc.   
147  https://thedocs.worldbank.org/en/doc/165711456838073531-0050022016/original/WDR16BPEstonianeGovecosystemVassil.pdf  
148  https://eur-lex.europa.eu/resource.html?uri=cellar:9d5c61bf-4629-11e7-aea8-01aa75ed71a1.0001.02/DOC_1&format=PDF  
149  Eurostat Structure of earnings survey, Labour Force Survey data for Non-Wage Labour Costs 
150  To improve clarity, the upper part of Table 4 covers the measures that are common in all policy options while the bottom part the 

measures that are included only in PO-B and PO-C.  

151  PM6 is expected to lead to additional training courses for GPs in all MS except for EL, HU, IT, LV, PL, RO and ES that are 
expected to continue to implement a stricter screening (medical assessment instead of screening) and for which a training of GPs 
to support the screening is not required. 

152  The EU average tariff per hour for a trainer is estimated at 150 EUR and the training is assumed to last 4 hours.   
153  Source: COWI, Ecorys and NTUA (2022), Impact assessment support study 

38 

 
  
  
  
  
  
  
  
  
 
 
 
 
  
                                                 
PO-A 

Difference to the baseline 
PO-B 

PO-C 

2030 

2050 

2030 

2050 

2030 

2050 

PM7 – advanced medical screening 

Administrative cost savings  

PM8 – removal of staging requirement    

44.8 
44.8 

53.8 
53.8 

3.1 
44.8 
44.8 

3.4 
53.8 
53.8 

Administrative cost savings for road transport operators. In PO-B and PO-C, the removal of the 
requirement to hold a licence of category C or D to obtain a licence of category CE or DE (PM8) is 
expected to  lead to  administrative cost  savings  for professional  drivers that  benefit  road transport 
operators. The removal of this requirement would lead to a reduction in the number of theoretical and 
practical  tests  required  to  obtain  a  CE  or  DE  category  licence,  estimated  at  469,349  in  2030  and 
572,082 in 2050, relative to the baseline. The administrative cost savings for road transport operators 
in PO-B and PO-C are thus estimated at EUR 44.8 million in 2030 and EUR 53.8 million in 2050 
relative to the baseline154 (see Table 4). Expressed as present value over the 2025-2050 horizon (in 
2021 prices), total administrative cost savings for road transport operators are estimated at EUR 875.3 
million in PO-B and PO-C. 

For the purpose of reporting on the application of the ‘one in, one out’ approach155, the annual average 
reduction in the number of theoretical and practical tests for 2025-2050 has been estimated at 510,474 
relative to the baseline in both PO-B and PO-C and the annual average cost savings for 2025-2050 at 
EUR 48.5 million156, which implies an average cost per theoretical and practical test for a C and D 
category licence of 95 EUR.  

6.1.3 

Impact on citizens  

In terms of benefits for citizens, the initiative will increase the assurance that drivers on EU roads 
have the skills, knowledge, experience, and risk awareness, are physically and mentally fit to drive 
and that their behaviour is not dangerous. Ensuring a high level of safety is important for all road 
users.  It  will  also  have  positive  effects  on  road  transport  operators,  driving  schools  and  law 
enforcement authorities, since their employees and civil servants will be less exposed to safety risks.  

The initiative will also remove barriers affecting persons when obtaining or exercising driving rights, and 
the most important effect will result from the introduction of mobile driving licences, which is common 
to  all  policy  options.  It  will  allow  the  drivers  seamless  interaction  with  authorities  when  exchanging 
information on driving rights. Regarding the risk of exclusion for certain category of population potentially 
resulting from the introduction of the EU mobile driving licences, the measure has been designed according 
to the “digital by default” principle. It envisages that physical driving licences will continue to be issued 
upon request and without conditions. Persons with less access to digital technology will continue to be able 
to prove their driving rights with physical driving licences. This would also be the case for drivers who 
travel abroad in countries where the EU mobile driving licence is not recognised.   

In addition, PO2 and PO3 will include other measures that will affect targeted groups of citizens, in 
particular holders of driving licences transferring to other EU countries, applicants that are not fluent 

154  The average cost per theoretical test for a category C licence is estimated at EUR 42, based on data for 17 Member States, and the 
average cost per practical test at EUR 134. For a category D licence, the average cost per theoretical test is estimated at EUR 43, 
based on data for 17 Member States, while the average cost per practical test at EUR 136. For the Member States for which data 
was not available, the average cost per test for the 17 Member States has been used.  

155  https://ec.europa.eu/info/law/law-making-process/planning-and-proposing-law/better-regulation-why-and-how_en  
156  Both the annual reduction in the number of tests and the annual costs savings are calculated as simple averages over 2025-2050 

for the purpose of ‘one in, one out’. 

39 

 
  
 
 
  
  
 
 
  
 
                                                 
in the language of their host country, or young persons willing to become professional drivers. PO2 
and PO3 will also introduce measures allowing faster access to licences of category CE or DE for 
professional drivers across the EU, which will reduce barriers to access to the driver profession.  

The specific rules related to the concept of normal residence, which are included in all three policy 
options, will also help persons transferring their normal residence to another Member State. Even if 
the number of persons facing unnecessary or unjustified procedures is rather low, consequences for 
each individual can be significant. Clarification of the concept of normal residence should solve the 
problem of determining the issuing authority just after the transfer of residence and it is expected to 
contribute positively to the freedom of movement. 

Simplification of rules on administrative validity will put the holders of EU driving licences on 
equal  footing,  regardless  in  which  country  they  apply  for  or  extend  the  licence  and  facilitate  the 
exchange of driving licences by issuing authorities that will not be faced with driving licences with 
validity  periods  different  from  those  they  apply  (included  in  PO1,  PO2  and  PO3).  The  mutual 
recognition of optional equivalences will allow holders of driving licences to enjoy rights granted by 
an optional equivalence also in other Member States applying the same rules (all three policy options 
include this measure). 

Due to the alignment to the latest legislation on the protection of personal data and the use of the 
eIDAS features for the EU mobile driving licence, which will be included in all three policy options, 
citizens will benefit from a high level of security and privacy of the information handled. Regarding 
the possible introduction of a QR code (included in in PO1, PO2 and PO3), the same approach on 
data protection as the one for the microchip on a physical driving licence will apply: the QR code 
will provide access to the same information as the one on the physical driving licence. In any case, it 
will not be possible to access the information without a visual access to the physical driving licence. 

The  mutual  recognition  of  driving  disqualifications,  provided  in  PO2  and  PO3,  will  give 
procedural safeguards to non-resident drivers who commit road safety traffic offences and ensure 
that their fundamental rights are respected. PO2 and PO3 will also have a positive impact on the right 
of non-discrimination, given they will provide flexibility for the first issuance of driving licences in 
case of restrictions related to languages which will allow applicants to choose where to take the tests.  

Administrative cost savings for citizens. Two policy measures lead to administrative cost savings 
(PM2c and PM12). PM2c (introduction of rules to remove restrictions associated to automatic gear 
transmission) is common to the three policy options, while PM12 (rules on the removal of Code 70) 
is only included in PO-C. 

In the baseline scenario, the applicants for a B licence need to conduct a complete test with a vehicle 
with manual transmission if they want to remove the restrictions (Code 78) on their driving licences 
issued following a driving test with a vehicle with an automatic transmission. In PMc2 it is assumed 
that  the  conditions  to  remove  Code  78  will  be  lighter  (shorter  test  or  certified  training).  PMc2  is 
expected to only affect holders of a Code 78 licence157 that would like to have this code removed. In 
the baseline scenario, the number of practical tests for a Code 78 licence is projected to increase to 
1.6  million  at  EU  level  by  2030  and  8.1  million  by  2050,  driven  by  the  uptake  of  zero-emission 
vehicles with automatic transmission. In Germany, some 450 tests are conducted annually to have 
Code  78  removed.  This  represents  around  0.9%  of  the  Code  78  tests158.  In  PMc2  the  number  of 

157  The harmonised Union code 78 imposes a restriction on holders of such a licence, in the sense that they can only drive a vehicle 

with automatic transmission. 

158  https://www.bundesrat.de/SharedDocs/drucksachen/2020/0501-0600/579-20.pdf?__blob=publicationFile&v=1  

40 

 
                                                 
practical tests for removing Code 78 would decrease by 0.9% in 2025, 0.1% in 2030 and 0% by 2050 
relative to the baseline. The reduction is significantly lower post-2025 because of the increasing share 
of vehicles with automatic transmission and thus the limited need to be able to drive a vehicle with 
manual transmission. PMc2 would result in a decrease in the number of practical tests at EU level by 
1,019 in 2030 and 714 in 2050 relative to the baseline. The administrative cost savings for citizens 
are estimated at EUR 0.09 million in 2030 and EUR 0.07 million in 2050 relative to the baseline (see 
Table  5).  Altogether,  citizens  are  expected  to  benefit  from  administrative  cost  savings  due  to 
removing  restrictions  associated  to  automatic  gear  transmission,  estimated  at  EUR  2.3  million 
expressed as present value over 2025-2050 relative to the baseline in all three policy options.  

For the purpose of reporting on the application of the ‘one in, one out’ approach, the annual average 
reduction in the number of practical tests for 2025-2050 has been estimated at 1,184 relative to the 
baseline in PO-A, PO-B and PO-C for PMc2 and the annual average decrease in the administrative 
costs for 2025-2050 at EUR 0.1 million159, implying an average cost per practical test of EUR 92. 

In the baseline, holders of a third country licence are restricted via code 70. Other EU Member States 
may decide not to recognise the licence. As such, these holders may have to conduct a driving test 
(theoretical  and  practical)  to  be  able  to  obtain  an  EU  licence  when  changing  residence.  In  PM12 
(included in PO-C), code 70 is assumed to be removed from the licence when the driver has been 
holding an EU licence for at least 5 years and has not committed serious road traffic offenses. By 
implementing PM12, it is expected that fewer holders of a third country licence would conduct a 
driving test to obtain an EU licence that can also be exchanged when the holder changes residence. 
Thus, the number of tests is estimated to decrease by 7,235 in 2030 and 7,552 in 2050 relative to the 
baseline. The administrative cost savings for citizens are estimated at EUR  1 million in 2030 and 
EUR 1.1 million in 2050 relative to the baseline (see Table 5). Expressed as present value over the 
2025-2050 period, they are estimated at EUR 19.3 million relative to the baseline (in 2021 prices) in 
PO-C. 

For the purpose of reporting on the application of the ‘one in, one out’ approach, the annual average 
reduction in the number of theoretical and practical tests for 2025-2050 has been estimated at 7,353 
relative to the baseline in PO-C for PM12 and the annual average reduction in the administrative 
costs  for  2025-2050  at  EUR  1.1  million160,  which  implies  an  average  cost  for  the  theoretical  and 
practical test of 143 EUR. 

Table 5: Costs and cost savings for applicants/holders of driving licences in the POs relative to the baseline scenario 
(EU27), in million EUR (2021 prices)161 

Adjustment costs  

PMc1 – updated standards on skills 

Administrative cost savings  

PMc2 – rules on gear transmission 

Adjustment cost savings  

PMc5 – updated medical standards 

Hassle cost savings  

Difference to the baseline 

PO-A 

PO-B 

PO-C 

2030 

2050 

2030 

2050 

2030 

2050 

2.8 
2.8 
0.09 
0.09 
136.0 
136.0 
72.7 

2.9 
2.9 
0.07 
0.07 
130.3 
130.3 
116.0 

2.8 
2.8 
0.09 
0.09 
136.0 
136.0 
72.7 

2.9 
2.9 
0.07 
0.07 
130.3 
130.3 
116.0 

2.8 
2.8 
0.09 
0.09 
136.0 
136.0 
72.7 

2.9 
2.9 
0.07 
0.07 
130.3 
130.3 
116.0 

159  Both the annual reduction in the number of tests and the annual cost savings are calculated as simple averages over 2025-2050 for 

the purpose of ‘one in, one out’. 

160  Both the annual reduction in the number of tests and the annual cost savings are calculated as simple averages over 2025-2050 for 

the purpose of ‘one in, one out’. 

161  Source: COWI, Ecorys and NTUA (2022), Impact assessment support study 

41 

 
  
                                                 
PMc9 – EU mobile driving licence 

72.7 

116.0 

72.7 

116.0 

72.7 

116.0 

Difference to the baseline 

PO-A 

PO-B 

PO-C 

2030 

2050 

2030 

2050 

2030 

2050 

Adjustment costs  

PM6 – simple medical screening 

Low 
High 

PM7 – advanced medical screening 

Low 
High 

Adjustment cost savings  

PM6 – simple medical screening 

Administrative cost savings  
PM12 – removal of code 70 

24-47.8 

43.8-68.3  369.9-502.5  440.4-578.8 

24.0 
47.8 

43.8    
68.3    

131.0 
131.0 

124.2    
124.2    

369.9 
502.5 

440.4 
578.8 

1.0 
1.0 

1.1 
1.1 

Adjustment costs for citizens. In all policy options (PO-A, PO-B and PO-C), the update of standards 
on  skills  and  knowledge  for  the  first  issuance  of  a  driving  licence  (PMc1)  is  expected  to  lead  to 
adjustment costs for applicants for a B category licence. PMc1 will extend the range of issues subject 
to testing, including knowledge of new vehicle features (safe use of Advanced Driving Assistance 
System/automation) as well as perception of hazardous situations, understanding of risk factors in 
normal traffic situations (including the presence of new vulnerable road users such as e-scooters) and 
knowledge of the safety of zero emission vehicles (e.g. chemical and explosion risks in the event of 
fire affecting an electric vehicle). It is likely to result in adjustment costs for applicants, especially 
concerning the theoretical test. This is because applicants are to be tested on more subjects. Especially 
the Hazard Perception Test (HPT) that is conducted separately from a theoretical test might result in 
fewer passing the test and the need to retake the test. Belgium, Germany, Finland and the Netherlands 
have already introduced the HPT and they are assumed to continue to implement it in the baseline 
scenario. At EU level, PMc1 is estimated to lead to an increase in the number of theoretical tests, due 
to a drop in the passing rate and the need to retake the test, by 74,174 in 2030 and 75,382 in 2050. 
This would lead to an increase in the costs for the first issuance of the licence for those that need to 
retake the test (estimated at EUR 2.8 million in 2030 and EUR 2.9 million in 2050 relative to the 
baseline162 (see Table 5163). As acknowledged in the evaluation support study164, the data collected 
on the costs of driving licences for the first application cover both the theoretical and practical tests, 
as well as the cost of the licence itself165. Expressed as present value over the 2025-2050 period, the 
adjustment costs for consumers in PO-A, PO-B and PO-C are estimated at EUR 52.5 million relative 
to the baseline (in 2021 prices). 

Two  additional  measures  (PM6  and  PM7),  included  in  PO-B  and  PO-C  respectively,  lead  to 
adjustment  costs  for  citizens.  Both  PM6  (rules  on  simple  medical  screening)  and  PM7  (rules  on 
advanced medical screening) include the screening of fitness to drive for each driver renewing its 
driving licence independent of age, possible or mandatory more frequent screening for elderly drivers 
and a vision test for applicants. In PO-B, the adjustment costs for citizens are estimated at EUR 24 

162  The average cost for a theoretical test is estimated at EUR 38, based on information obtained for 17 Member States (i.e. ranging 
between EUR 7 EUR for Poland to EUR 110 for Portugal). For the other Member States, the average cost for a theoretical test has 
been used for estimating the costs. 

163  To improve clarity, the upper part of Table covers the measures that are common in all policy options while the bottom part the 

measures that are included only in PO-B and PO-C.  

164  Support study to the ex-post evaluation of Directive 2006/126/EC on Driving Licences - Publications Office of the EU (europa.eu) 
165  The costs related to the tests and the licence cannot be separated.  

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to 47.8 million in 2030 and EUR 43.8 to 68.3 million in 2050 relative to the baseline, while in PO-C 
they are estimated at EUR 369.9 to 502.5 million in 2030 and EUR 404.4 to 578.8 million in 2050 
relative  to  the  baseline  (see  Table  5).  Expressed  as  present  value  over  the  2025-2050  period,  the 
adjustment costs for citizens are estimated at EUR 663.6 to 1,106.6 million relative to the baseline 
(in  2021  prices)  in  PO-B  and  EUR  7,472.4  to  9,960.9  million  PO-C.  The  significant  difference 
between  PO-B  and  PO-C  comes  from  the  rules  related  to  the  administrative  validity  of  driving 
licences  for  category  A  and  B  for  elderly  drivers.  In  PO-C  the  administrative  validity  of  driving 
licences for drivers above 65 years old is shortened to 5 years, which results in an increase in the 
number of medical checks at EU level (i.e. by 2.6 million in 2030 and 3.2 million in 2050 relative to 
the baseline)  and thus  significant  adjustment costs for citizens. On the other hand, in  PO-B more 
frequent medical screening for drivers above 70 years old results in  a reduction in the number of 
medical checks at EU level (i.e. by 3.6 million in 2030 and 3.4 million in 2050 relative to the baseline) 
and is thus reported in the following section. The reduction in the number of medical checks results 
from the change of the minimum age from which a more frequent assessment of elderly drivers can 
be required. The current Directive specifies a minimum age of 50 years while PM6 and PM7 specify 
respectively  an  age  of  70  and  65  years.  The  requirement  of  mandatory  frequent  tests  will  have  a 
limited effect considering the number of drivers aged 65 and above, and the fact that a number of 
Member States currently apply more frequent assessments of elderly drivers at ages higher than 50 
years.The impact of these two measures on the number of medical checks depends on the baseline 
situation in each Member State. The differences between adjustment costs for the screening of fitness 
to drive when renewing the driving licence independent of age and the vision test also play a role in 
the difference between PO-B and PO-C. Detailed explanations for PM6 and PM7 at Member State 
level are provided in Annex 4.  

Adjustment cost savings for citizens. Two measures (PMc5 and PM6) lead to adjustment cost savings 
for citizens. PMc5 (update of standards on physical and mental fitness to be met for the issuance of 
driving licences) is common to the three policy options, while PM6 is included in PO-B. In PMc5, 
less frequent medical checks of drivers suffering from diabetes (every 10 years instead of 5) taking 
into account the evolution of medical care for this disease, are estimated to lead to a reduction in the 
number of medical tests by 2.3 million in 2030 and 2.2 million in 2050 relative to the baseline. The 
adjustment cost savings for citizens are estimated at EUR 136 million in 2030 and EUR 130.3 million 
in  2050  relative  to  the  baseline,  in  PO-A,  PO-B  and  PO-C.  The  changes  in  the  rules  for  the 
consultation  of  the  GP  for  elderly  people  (above  70  years  old)  lead  to  adjustment  cost  savings 
estimated at EUR 131 million in 2030 and EUR 124.2 million in 2050 relative to the baseline for 
PM6 (PO-B), due to the reduction in the number of medical checks (i.e. by 3.6 million in 2030 and 
3.4 million in 2050 relative to the baseline). Citizens are expected to benefit from adjustment cost 
savings due to less frequent medical checks for drivers suffering from diabetes (every 10 years instead 
of  5)  and  changes  in  the  rules  for  the  consultation  of  the  general  practitioners  for  elderly  people 
(above 70 years old), estimated at EUR 2,477.5 million relative to the baseline (in 2021 prices) in 
PO-A and PO-C and at EUR 4,891.4 million PO-B. 

Hassle cost savings for citizens. PMc9 (introduction of the EU mobile driving licence), included in 
all three policy options, is estimated to lead to a reduction in hassle costs for the renewal of category 
A and B licences166. A World Bank study167 on the Estonian e-Government system conservatively 
estimated that each renewal request saved 15 minutes on average compared to the case where the 
system was not in place. The hassle cost savings for citizens are estimated at EUR 72.7 million in 
2030 and EUR 116 million in 2050 relative to the baseline (see Table 5). Expressed as present value 

166  These costs relate for example to the waiting time for picking up the physical licence, etc. 
167  https://thedocs.worldbank.org/en/doc/165711456838073531-0050022016/original/WDR16BPEstonianeGovecosystemVassil.pdf  

43 

 
                                                 
over the 2025-2050 horizon (in 2021 prices), total hassle cost savings for citizens are estimated at 
EUR 1,697.2 million in PO-A, PO-B and PO-C. 

Overall, PO-A and PO-B would result in net cost savings (i.e. benefits) for citizens estimated at 
EUR 4,124.4 million in PO-A and at EUR 5,431.8 to 5,874.7 million in PO-B, expressed as present 
value over the 2025-2050 horizon. On the other hand, PO-C would result in net costs for citizens 
estimated at EUR 3,328.7 to 5,817.2 million expressed as present value relative to the baseline. 

6.1.4 

Impact on SMEs 

The initiative is relevant for SMEs, specifically for road transport operators, general practitioners and 
driving schools.  

As explained in section 6.1.2, all policy options are expected to result in a reduction of hassle costs 
for road transport operators, 99% of them being SMEs (enterprises employing up to 250 people and 
with a turnover of less than EUR 50 million168,169,170), due to the implementation of the introduction 
of the EU mobile driving licence for the C and D categories.  

The hassle cost savings are estimated at EUR 32.8 million in 2030 and EUR 38.7 million in 2050 
relative to the baseline (see section 6.1.2). Expressed as present value over the 2025-2050 horizon 
(in  2021  prices),  total  hassle  cost  savings  for  road  transport  operators  are  estimated  at  EUR  587 
million in PO-A, PO-B and PO-C. In addition, PO-B and PO-C would result in administrative cost 
savings  for  road  transport  operators  due  to  the  removal  of  the  requirement  to  hold  a  licence  of 
category C or D to obtain a licence of category CE or DE (PM8). The administrative cost savings for 
road transport operators in PO-B and PO-C are estimated at EUR 44.8 million in 2030 and EUR 53.8 
million in 2050 relative to the baseline (see section 6.1.2). Expressed as present value over the 2025-
2050 horizon (in 2021 prices), the cost savings are estimated at EUR 875.3 million in PO-B and PO-
C relative to the baseline. Thus, all policy options would lead to a reduction in costs for road transport 
operators, although the impacts of PO-B and PO-C would be higher than those of PO-A.  

On  the  other  hand,  PO-B  and  PO-C  are  expected  to  result  in  additional  costs  for  general 
practitioners, linked to the need to follow training on fitness to drive. Indeed, general practitioners 
are usually working as independent or as part of a health centre that employs less than 250 persons. 
Therefore,  they  fall  under  the  EUROSTAT  definition  of SMEs.  The  adjustment  costs  for  general 
practitioners are estimated at EUR 3.1 million in 2030 and EUR 3.4 million in 2050 relative to the 
baseline in PO-B and PO-C. Expressed as present value over the 2025-2050 horizon (in 2021 prices), 
total adjustment costs for general practitioners are estimated at EUR 57.7 million in both PO-B and 
PO-C (see section 6.1.2).  

Another  group  of  small  and  medium-sized  businesses  to  be  affected  by  the  initiative  will  be  the 
driving schools’ sector.  Driving schools will  continue to have the opportunity to  offer training to 
applicants for a driving licence but with further harmonisation of the different categories of driving 
licences they are expected to gain additional work opportunities in all policy options (PO-A, PO-B 
and  PO-C).  The  overall  impact  of  the  initiative  on  driving  schools  is  expected  to  result  from  the 
combination of two direct effects:  

168  See Commission Recommendation 2003/361/EC of 6 May 2003 concerning the definition of micro, small and 

medium-sized enterprises, OJ L 124, 20.5.2003, p. 36. 

169  https://eur-lex.europa.eu/resource.html?uri=cellar:9d5c61bf-4629-11e7-aea8-01aa75ed71a1.0001.02/DOC_1&format=PDF   
170  https://ec.europa.eu/eurostat/databrowser/view/SBS_SC_1B_SE_R2__custom_3493320/default/table  

44 

 
                                                 
-  The  update  of  standards  and  rules  will  result  in  costs  to  update  the  curricula.  However, 
introducing rules on training has been discarded (see Annex 5). Consequently, the changes 
will be limited and could be dealt with at a limited cost via the periodic updates performed 
notably to align with new traffic rules; 

-  The  actions  taken  to  facilitate  the  access  to  categories  of  licence  relevant  to  professional 
drivers  will  increase  marginally  the  number  of  persons  passing  the  tests  and  therefore  the 
opportunity to supply training services. 

In  addition,  the  rule  related  to  automatic  gear  transmission  (PMc2),  included  in  the  three  policy 
options, is expected to indirectly have a positive impact on SME. On the one hand, according to views 
provided by driving schools in the context of the consultation activities, applicants are not willing to 
train and pass the driving test on a vehicle with an automatic gear transmission because of the need 
to undergo an additional complete test to be able to drive vehicles with manual gear transmission. On 
the other hand, as underlined in the section on problems, the offer has already started to decrease for 
first-hand vehicles with manual gear transmission considering the target of 100% of new cars to be 
zero emission in 2035, as proposed by the Commission as part of the “Fit for 55” package. PMc2, 
included in all options, will address this inconsistency between the evolution of the vehicle market 
and  of  customer  demand.  It  will  allow  for  a  simpler  removal  of  restrictions  on  driving  licences 
obtained following a driving test on a vehicle with automatic gear transmission with a training or a 
test focusing strictly on skills and knowledge that are different when driving vehicles with manual or 
automatic gear transmission. It will have a positive impact on driving schools allowing them to adapt 
their business and their vehicle fleet, in line with the EU policy on alternative-fuelled vehicles. 

6.1.5  Digital by default  

All policy options will have a positive impact on the application of the 'digital by default' principle, 
introduced by the common measure on the EU digital driving licence (PMc9). The driving licence 
under all options will be issued in digital format by default from 2028. Therefore, the administrative 
procedures involving driving licences will be conducted digitally and the private sector will also be 
able to develop on-line solutions when driving rights should be proven. However, it should be noted 
that it will remain necessary to keep the possibility to issue physical driving licences (for example 
when the driver is to travel to a third country where the digital driving licence is not recognised). 
Another measure which will also contribute to the digital principle is the introduction of a possible 
QR code on the physical licence in the areas currently reserved for a microchip (PMc10), which will 
provide access to additional information, not displayed on the physical driving licence, and is also 
common to all three options. This measure will benefit from the infrastructure to be implemented to 
support the mobile driving licences (PMc 9). It will indeed rely on the same type of API for licence 
registry as used by the mobile driving licences. In addition, the improvement of RESPER (PMc4) 
will  increase  the  use  of  digital  means  by  administrations  with  indirect  benefits  for  the  holders  of 
driving licences. Finally, a special attention will be given to removing potential obstacles to digital 
training  and  testing,  when  it  does  not  negatively  affect  road  safety,  notably  when  updating  the 
standards on skills and knowledge (PMc1), introducing training of general practitioners (PM6 and 
PM7) and the rules to remove Code 78 related to gear transmission (PMc2).  

6.1.6 

Impact on the functioning of the internal market and on competition 

Internal market. All policy options are expected to have a positive impact on the functioning of the 
internal market, by removing unnecessary barriers for applicants and holders of driving licences and 
facilitating the free movement of people. All options will specify how the normal residence should 
be determined during the first six months of establishment in a new country (PMc8). They will also 
include the mutual recognition of the new equivalence applicable to small buses combined with a 

45 

 
trailer  (PMc12)  and  introduce  mobile  driving  licences  (PMc9),  which  will  rely  on  the  ISO/IEC 
18013-5 standard. This will ensure interoperability of the mobile driving licences issued by each EU 
Member State and their recognition in the EU and abroad.  

The positive impact of PO-B and PO-C is however expected to be higher than that of PO-A, as these 
two options will introduce measures allowing faster access to licences of category CE or DE (PM8). 
They also include additional optional equivalences (PM11 and PM13) that will apply only on the 
territories of Member States implementing them and are not expected to distort the market. PO-C 
would have further positive impact on the functioning of the internal market by introducing rules for 
the exchange of driving licences issued by a third country whose licensing system guarantees a level 
of road safety equivalent to the one in the EU (PM14). In addition, this policy option introduces a 
mutual  recognition  of  physical  and  mental  assessments  (PM10),  with  a  potential  positive  impact, 
albeit indirect, on the free movement of people. 

The implementing rules related to the concept of normal residence would also avoid specific cases 
when a person transferring his or her normal residence to another Member State may have to wait 
several months to have his or her issuing authority identified. While there is no direct impact of these 
last measures on the functioning of the internal market and on competition, a positive indirect impact 
can be expected.  

Competitiveness. As explained in section 6.1, all policy options are expected to lead to hassle cost 
savings for road transport operators since the introduction of the EU mobile driving licence (PMc9), 
included in all three policy options, is estimated to lead to a reduction in hassle costs for the renewal 
of the category C and D licences. In addition, in PO-B and PO-C, the removal of the requirement to 
hold a licence of category C or D to obtain a licence of category CE or DE (PM8) is expected to lead 
to administrative cost savings for professional drivers that benefit road transport operators. Therefore, 
it can be concluded that all three policy options improve the competitiveness of the road transport 
operators, the expected impact being higher in PO-B and PO-C than in PO-A.  

6.2  6.2 

Social impact 

The social impact is assessed in terms of impacts on road safety and impacts on the protection of 
fundamental rights. 

6.2.1 

Impacts on road safety 

With regard to the impacts in terms of lives saved and serious injuries avoided, the estimates take 
into account the overlapping impacts between measures.  

In addition, conservative assumptions have been used for deriving the impacts, as explained in Annex 
4 (section 7). The multiple causes of accidents and the limited availability of a complete dataset leads 
to uncertainty, as already explained in section 2.1.1. Moreover, Member States play an important role 
in the implementation and enforcement of the rules on driving licences. 

Table 6 provides the expected reduction in the number of fatalities and serious injuries relative to the 
baseline in 2030 and 2050, while Table 7 shows the cumulative number of lives saved and injuries 
avoided relative to the baseline over the 2025-2050 horizon.  

46 

 
Table 6: Reduction in the number of fatalities and injuries in the POs relative to the baseline, in 2030 and 2050171 

Fatalities 
Serious injuries 
Total fatalities and injuries avoided 

PO-A 

Difference to the baseline 
PO-B 

PO-C 

2030 
3 
29 
32 

2050 
3 
28 
31 

2030 
51 
488 
539 

2050 
44 
419 
463 

2030 
79 
755 
834 

2050 
68 
649 
717 

In PO-A, the updated standards on skills and knowledge (PMc1) are estimated to have a significant 
positive impact on road safety. On the other hand, the harmonisation of the administrative validity of 
category A and B licences to 15 years (PMc11) would reduce the frequency of certain medical tests 
and thus result in limited negative effects. Overall, PO-A results in 3 lives saved in 2030 and in 2050 
relative  to  the  baseline,  and  28-29  serious  injuries  avoided  (see  Table  6).  Cumulatively,  over  the 
2025-2050  horizon  48  lives  are  estimated  to  be  saved  (less  than  0.1%  reduction  relative  to  the 
baseline) and 466 serious injuries avoided.   

The positive impact on road safety  would  be higher in  PO-B, due to  the  introduction of rules on 
training  and  probation  period,  with  a  probation  period  for  novice  drivers  (PM1),  the  mutual 
recognition of driving disqualifications (PM4)  and the rules on medical screening and assessment 
(PM 6). In PO-B, the number of lives saved are estimated at 51 in 2030 and 44 in 2050 relative to the 
baseline, and the number of serious injuries avoided at 488 in 2030 and 419 in 2050. Cumulatively, 
over the 2025-2050 horizon 1,153 lives  are  estimated to  be saved (0.3% reduction relative to the 
baseline) and 11,020 serious injuries avoided in PO-B relative to the baseline. 

PO-C goes one step further with more advanced rules on driving disqualifications (PM5) and medical 
fitness (PM7), resulting in 79 lives saved in 2030 and 68 lives saved in 2050. In addition, the number 
of  serious  injuries  avoided  is  estimated  at  755  in  2030  and  649  in  2050  relative  to  the  baseline. 
Cumulatively, over the  2025-2050 horizon  1,837 lives are estimated to  be saved  (0.5% reduction 
relative to the baseline) and 17,562 serious injuries avoided in PO-C relative to the baseline.  

The other measures included in the policy options are expected to have a marginal positive or neutral 
effect on road safety and their impacts are not further quantified. A detailed qualitative assessment is 
provided in Annex 10. 

Thus, all policy options result in a reduction in the number of fatalities and injuries relative to the 
baseline scenario. PO-C shows the highest reduction relative to the baseline, followed by PO-B and 
PO-A.  The  impact  in  2025  (the  first  year  of  the  assumed  application  of  the  revised  Directive)  is 
assumed  to  be  zero  as  the  behavioural  change  is  only  expected  in  the  year  following  that  of  a 
successfully implementation. As the number of road victims in the baseline is decreasing over time 
(mainly due to the deployment of intelligent speed assistance systems which is expected to lead to 
fewer speed-related accidents), the impact of the revised Directive in  relation to the baseline also 
decreases over time. 

Table 7: Cumulation reduction in the number of fatalities and injuries in the POs relative to the baseline, for 2025-
2050172 

Fatalities 
Serious injuries 

PO-A 

PO-B 

PO-C 

48 
466 

1,153 
11,020 

1,837 
17,562 

171  Source: COWI, Ecorys and NTUA (2022), Impact assessment support study 
172  Source: COWI, Ecorys and NTUA (2022), Impact assessment support study 

47 

 
  
 
 
                                                 
Total fatalities and injuries avoided 

514 

12,173 

19,399 

Table 8 provides the reduction in the external costs of accidents relative to the baseline, expressed as 
present value over the 2025-2050 horizon, in 2021 prices. The 2019 Handbook on the external costs 
of transport173 has been used to monetise the costs. According to the Handbook, the external cost of 
a fatality in 2021 prices is estimated at around EUR 3.6 million and that of a serious injury at around 
EUR 0.5 million.  

Table 8: Reduction in the external costs of accidents in the POs relative to the baseline, expressed as present value 
over the 2025-2050 horizon, in 2021 prices (million EUR)174 

Fatalities 
Serious injuries 
Total fatalities and injuries 

PO-A 

PO-B 

PO-C 

123.3 
182.6 
305.9 

2,896.1 
4,216.4 
7,112.6 

4,611.7 
6,715.0 
11,326.7 

As a result of the positive impacts on lives saved and injuries avoided presented above, PO-C shows 
the highest  impact  in  terms  of reduction in  the external  costs of accidents relative to  the baseline 
(expressed as present value over the 2025-2050 horizon), estimated at EUR 11.3 billion. It is followed 
by PO-B with EUR 7.1 billion and PO-A with EUR 0.3 billion.  

6.2.2 

Impact on fundamental rights 

The policy options were assessed to determine if they have an impact on the fundamental rights and 
equal treatment of EU citizens. The starting point of the assessment of the fundamental rights is the 
Charter  of  Fundamental  Rights  of  the  European  Union175.  The  assessment  identified  several 
potentially relevant fundamental rights: protection of personal data (Article 8), non-discrimination 
(Article 21) and freedom of movement and residence (Article 45). In addition, the assessment was 
also made regarding equal treatment, which goes beyond the fundamental right of non-discrimination 
and ensures that resident and non-resident offenders are treated in the same way.  

All policy options will be aligned with the latest legislation on the protection of personal data (GDPR 
and  Regulation  (EU)  No  2018/1725)  through  the  improvement  of  RESPER,  the  network  for  the 
exchange of information on driving licences (PMc4) and through establishing the EU digital driving 
licence (PMc9). The clear definition of the cases where RESPER can be used will remove the existing 
legal  ambiguities  which  constitute  a  risk  on  the  personal  data  of  drivers.  The  use  of  the  eIDAS 
features for the EU driving licence, in particular  the electronic identity for enrolment  and  the EU 
Wallet for the storage and exchange of data will ensure a high level of security and privacy of the 
information  handled.  It  should  be  however  highlighted  that  the  increased  use  of  digital  tools  will 
result in new privacy risks. 

The transition to the EU digital driving licence is not expected to exclude certain categories of the 
population. Indeed, while the digital driving licence will be issued by default, everyone will be able 
to obtain a physical driving licence by choice.  

Although the number of persons having their freedom of movement hindered because of unnecessary 
or unjustified procedures related to driving licences may be low, the consequence for individuals can 

173  https://op.europa.eu/en/publication-detail/-/publication/9781f65f-8448-11ea-bf12-01aa75ed71a1  
174  Source: COWI, Ecorys and NTUA (2022), Impact assessment support study 
175  OJ C 326 of 26.10.2012 p.2 

48 

 
 
 
 
                                                 
be significant, when they cannot obtain or keep their driving rights. In that respect, all policy options 
are expected to contribute positively to the freedom of movement. The clarification of the concept of 
normal residence (PMc8) should solve the problem of determining the issuing authority just after the 
transfer of residence. The simplification of the rules on administrative validity (PMc11) will put the 
holders of EU driving licences on an equal footing, regardless in which country they apply for  an 
extension of the licence. The mutual recognition of optional equivalences (PMc12) will allow holders 
of driving licences to enjoy rights granted by an optional equivalence also in other Member States 
applying the same rules. The mutual recognition of driving disqualifications (PM4) and of rules on 
penalty points (PM5) will give procedural safeguards to non-resident drivers who commit road safety 
traffic  offences  and  ensure  that  their  fundamental  rights  are  respected.  A  positive  impact  on  the 
freedom  of  movement  is  foreseen  also  in  the  case  of  holders  of  driving  licences  issued  by  third 
countries (in case the licensing system of the third country concerned is similar to the one in the EU 
in terms of road safety), which will allow for easier access to EU driving licences. This latter could 
positively affect around 25,680 to 27,100 persons each year176. 

Besides these impacts on fundamental rights which are common to all three policy options, PO-C is 
expected to bring a positive impact to drivers from third countries holding an EU licence for at least 
5 years and not having committed serious road traffic offenses, as well as EU drivers with licences 
issued in third countries (but formerly holding an EU one). Code 70, which will be removed in such 
cases, concerns 7, 235 and 7,552 persons in 2030 and 2050 respectively177. 

PO-B and PO-C are also expected to have a positive impact on the right of non-discrimination, given 
they will provide flexibility for the first issuance of driving licences in case of restrictions related to 
languages (PM9), which will allow applicants to choose where to take the tests; it concerns between 
41,816 and 75,951 persons each year178. 

In  conclusion,  all  policy  options  contribute  to  the  protection  of  fundamental  rights  and  to  equal 
treatment of road users. However, given the number of drivers that are concerned by the additional 
measures on drivers from third countries and those concerned by the language provisions, PO-B and 
PO-C are expected to bring a higher positive impact.  

6.2.3 

Impact on fraud  

Regarding driving licence tourism, RESPER enables authorities to verify if driving rights exist or have 
been revoked in another country. In addition, the measure related to normal residence (PMc 8) would 
contribute to a reduction in the number of cases where a person can justify a normal residence in 
more than one country and abuse this situation to escape  from  the consequences  of  a road-traffic 
offense.  

Regarding fraud and forgery, the fraudsters also benefit from the evolution of technologies and the 
risk remains present, mainly linked to forged driving licences using old models. The obligation of 
the current Directive for all driving licences to comply with the new model (plastic card) by 2033 is 
expected to significantly mitigate the issue. In addition, the improvement of RESPER (PMc 4), in 
particular  in  terms  of  responsiveness,  should  help  the  police  in  the  verification  of  driving  rights, 
notably when suspecting a case of forgery. 

176  Source: COWI, Ecorys and NTUA (2022), Impact assessment support study 
177  See section 6.1.3 
178  Source: COWI, Ecorys and NTUA (2022), Impact assessment support study 

49 

 
                                                 
However, it  should be stressed that the  introduction of the EU  mobile driving licence  (PMc 9) is 
expected to have the biggest contribution to the fight against fraud and forgery. A wide deployment 
would indeed result in less time for verification (almost immediate with a digital driving licence) and 
therefore more time to assess the authenticity of physical driving licences. 

6.3  6.3 

Environmental impact  

All policy options are expected to have a positive impact on the environment, albeit a small one. By 
including new rules on automatic gear transmission and increasing the maximum mass for most of 
the  zero-emission  vehicles  in  category  B179,  they  will  facilitate  the  uptake  of  such  vehicles,  thus 
contributing to the objectives of the EU Smart and Sustainable Mobility Strategy180 and the European 
Climate Law181.  

Currently only large vans (including camper vans) over 3,500 kg are technically classed as a heavy 
goods vehicle (HGV), requiring a higher class of licence (category C or C1 instead of B). However, 
the same type of alternatively fuelled vehicles have an increased mass compared to their petrol and 
diesel counterparts. This is due to the additional weight of their powertrain, for example the battery. 
The amendment of the definitions of vehicle categories for cars and vans regarding maximum mass 
(PMc3) will allow holders of a category B driving licence to use alternatively fuelled vehicles (vans 
and campers) of up to 4,25t, without a trailer. It is expected to have a positive impact on the transition 
from fossil-fuelled vehicles for this category of road users.  

In  addition,  new  rules  on  automatic  gear  transmission  (PMc2)  should  contribute  positively  to  the 
transition  to  zero-emission  vehicles.  Indeed,  the  development  of  alternatively  fuelled  vehicles 
(hybrid, electric and hydrogen) will gradually lead to the prevalence of automatic transmission in 
vehicles.  Consultation  activities  have  shown  that  driving  schools  have  no  incentives  to  include 
automatic gear box cars for training, while the candidates do not want to undergo an additional full 
practical exam with a manual gear box to have removed the restriction on automatic gear only. Over 
time, automatic gear transmission will become the norm in the EU in line with the baseline scenario 
projections. Learners will do their driving training and tests increasingly in an automatic transmission 
vehicle  while  the  need  for  an  additional  driving  test  to  use  manual  transmission  will  decrease. 
Consequently, the new rule on automatic gear transmission (PMc2) will allow for more training on 
zero-emission vehicles during the transition from fossil-fuelled vehicles, indirectly contributing to 
this change. 

Finally, a marginal positive impact is expected from the introduction of digital driving licences by 
default from 2028 (PMc9), which means that drivers will no longer have to carry a physical licence 
anymore for driving in the EU (or in a third country recognising the EU digital driving licence). It 
was estimated182 that approximatively 130 tonnes of plastic (polycarbonate) can be saved annually 
because of the introduction of the digital licence. Moreover, the possibility to print a QR code in the 
space reserved on physical driving licences for a microchip (PMc10) is expected to reduce the amount 
of silicon used to produce the microchip by 0.2 tonnes per year. This development is also in line with 
the EU’s objective to become more independent in terms of supply chains of raw materials, as stated 

179  There is not necessarily the case of biofuels for example. 
180  COM(2020) 789 final https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX%3A52020DC0789  
181  Regulation(EU)  2021/1119  of  the  European  Parliament  and  of  the  Council  of  30  June  2021  establishing  the  framework  for 

achieving climate neutrality and amending Regulations (EC) No 401/2009 and (EU) 2018/1999 (OJ L 243, 9.7.2021, p. 1). 

182  Source: COWI, Ecorys and NTUA (2022), Impact assessment support study 

50 

 
                                                 
in the 2022 Strategic Foresight Report. Moreover, the initiative’s objective to increase the uptake of 
mobile driving licences is also likely to spur the twinning between the digital and green transitions183. 

The impact on the environment of the other policy measures is not expected to be significant and has 
not  been  quantified.  Following  the  analysis  above,  no  significant  harm  is  expected  on  the 
environment by any of the policy options. 

7 

7  HOW DO THE OPTIONS COMPARE? 

7.1  7.1 

Effectiveness 

The assessment of effectiveness looks at the extent to which the general and specific objectives (SO) 
of  the  intervention  are  met.  Table  9  provides  the  link  between  policy  objectives  and  assessment 
criteria. 

Table 9: Link between objectives and assessment criteria 
General 
objectives 

Specific objectives 

Assessment criteria  

general 
The 
objectives 
are:  
(i)  improve  road 
safety;  
(ii)  facilitate  the 
free  movement 
of persons in the 
European Union 

SO1  -  Improve  driving  skills,  knowledge 
and  experience  and  reduce  and  punish 
dangerous behaviour 

Standards on skills, knowledge, and probation periods to be met 
for the first issuance of a driving licence are harmonised 
Dangerous behaviour abroad is more coherently punished 

SO2 - Ensure adequate physical and 
mental fitness of drivers across the EU 

Drivers  are  regularly  medically  screened,  depending  on  their 
health status and age  

SO3 – Remove inadequate or unnecessary 
barriers affecting applicants and holders of 
driving licences 

Mobile driving licence recognised across the EU 
Removal  of  cases  where  normal  residence  is  an  obstacle  to 
exercise or maintain driving rights 

All options contribute to the general objectives by facilitating the free movement of all EU residents 
and by reducing the number of road traffic accidents, notably those involving novice drivers. PO-B 
is expected to result in a higher decrease of the number of accidents than PO-A for all drivers, and 
especially for novice drivers. All policy options will remove more obstacles to free movement, for 
applicants and for holders of driving licences. PO-C is more effective than PO-B and PO-A, because 
it is expected to bring an additional decrease of the number of road accidents and to facilitate the free 
movement also for former holders of licences issued in third countries having their residence in the 
EU. 

Concerning SO1, all options are expected to reduce road fatalities, notably those of novice drivers, 
with the update of the standards on skills and knowledge to be met at the driving test. PO-B and PO-
C are expected to perform better than PO-A with the expected reduction of road accidents for novice 
drivers  due  to  the  introduction  of  a  probation  period  and  related  stricter  rules  in  this  period.  In 
addition, both PO-B and PO-C will introduce a recommendation on lifelong training for all drivers. 
They are also expected to address impunity for dangerous behaviour on the  road while driving in 
another Member State by introducing the mutual recognition of driving disqualifications. PO-C is 
however expected to be the most effective, albeit only marginally, as an additional reduction of road 
accidents is expected due to rules on the recognition of penalty points for drivers committing offenses 
abroad. 

183  https://ec.europa.eu/info/strategy/strategic-planning/strategic-foresight/2022-strategic-foresight-report_en  

51 

 
 
                                                 
Concerning SO2, the effects of PO-A are expected to be marginal and they can mainly be attributed 
to  the  adaptation  to  medical  progress  while  monitoring  certain  diseases  (e.g.  diabetes).  PO-B  is 
expected to contribute to improving road safety  more, due to the mandatory screening of medical 
fitness at renewal, based on self-assessment, and more frequent medical screening for drivers aged 
70 years or more. PO-C is expected to be the most effective due to a more advanced medical screening 
and frequent verifications extended to drivers older than 65, which will be mandatory every 5 years. 

Concerning SO3, all options are expected to remove unnecessary barriers for applicants and holders 
of driving licences. The  main contribution  to  SO3 will  come from  the introduction of the mobile 
driving licence. All policy options will also resolve problems regarding normal residence faced by 
certain persons changing their residence to another Member State. PO-B and PO-C are expected to 
perform  better  than  PO-A  at  removing  the  unnecessary  barriers,  facilitating  the  access  to  driving 
licences  for  professional  drivers  and  for  applicants  which  are  not  fluent  in  the  language  of  their 
country of residence. They will also remove obstacles affecting holders of driving licences issued in 
certain third countries who will be able to obtain an EU driving licence when establishing in the EU. 
PO-C is  expected to  be marginally the most effective  in  addressing SO3, since it will  in addition 
remove  or  reduce  administrative  barriers  affecting  persons  which  are  not  covered  by  the  other 
options, notably former holders of licences issued in third countries who already established their 
residence in the EU and agricultural workers engaged in cross-border activities.  

7.2  7.2 

Efficiency 

Efficiency concerns "the extent to which objectives can be achieved for a given level of resource/at 
least cost". In all policy measures, the benefits outweigh by far the increase in costs, relative to the 
baseline. The costs and benefits are summarised in Table 10. 

Table  10:  Summary  of  costs  and  benefits  of  policy  options  –  net  present  value  for 2025-2050  compared  to  the 
baseline (in million EUR), in 2021 prices184 

PO-A 

Difference to the baseline 
PO-B 

PO-C 

Member States administrations 
Adjustment costs  
Enforcement costs  
Enforcement cost savings  
Administrative cost savings  
European Commission 
Adjustment costs - ongoing  
Citizens 
Adjustment costs  
Administrative cost savings  
Adjustment cost savings 
Hassle cost savings  
Businesses 
Adjustment costs  
Administrative cost savings  
Hassle cost savings  
Reduction in the external costs of accidents 
Total fatalities and injuries 
Fatalities 

63.2 
- 
2,830.6 
1,969.3 

0.6 

52.5 
2.3 
2,477.5 
1,697.2 

 - 
 - 
587.0 

305.9 
123.3 

63.2 
26.3 
2,830.6 
1,969.3 

0.7-1.1 

63.2 
75.3 
2,830.6 
1,969.3 

0.7-1.1 

716.2-1,159.1 
2.3 
4,891.4 
1,697.2 

7524.9-10,013.4 
21.5 
2,477.5 
1,697.2 

57.7 
875.3 
587.0 

7,112.6 
2,896.1 

57.7 
875.3 
587.0 

11,326.7 
4,611.7 

184  Source: COWI, Ecorys and NTUA (2022), Impact assessment support study 

52 

 
  
                                                 
Member States administrations 
Injuries 
Total costs 
Total benefits 
Net benefits 

PO-A 

Difference to the baseline 
PO-B 

PO-C 

182.6 
116.3 
9,869.7 
9,753.4 

4,216.4 
864.1-1,307.5 
19,965.7 
18,658.2-19,101.6 

6,715.0 
7,721.8-10,210.8 
21,785.1 
11,574.3-14,063.3 

The  major  cost  element  of  the  policy  options,  except  for  PO-A,  consists  of  adjustment  costs  for 
citizens related to the rules on medical screening (PO-B and PO-C). Other significant groups of costs, 
included in all policy options, are adjustment costs for Member States administrations for setting up 
the  technical  solutions  to  support  the  mutual  recognition  of  the  mobile  driving  licences  and 
administrative costs for citizens related to the updating of standards on skills and knowledge to be 
met for the first issuance of a driving licence.  

PO-A, including only measures common to all options, shows the lowest total costs estimated at EUR 
116.3  million  relative  to  the  baseline,  expressed  as  present  value  over  2025-2050.  PO-B  shows 
significantly  higher  costs,  estimated  at  EUR  864.1  to  1,307.5  million  relative  to  the  baseline, 
expressed as present value over 2025-2050. The main difference in terms of costs between PO-A and 
PO-B  is  due  to  the  rules  on  simple  medical  screening  and  the  mutual  recognition  of  driving 
disqualifications in PO-B. PO-C shows the highest total costs estimated at EUR 7,721.8 to 10,210.8 
million relative to the baseline, expressed as present value over 2025-2050. Again, the difference in 
costs between PO-B and PO-C is driven mainly by the rules on medical screening, which become 
more stringent at renewal and the medical screening becomes more frequent after a driver reaches 
the age of 65, and to lower extent by the rules on consequences of penalty points for non-residents. 

All  policy  options  show  significant  total  benefits,  linked  to  the  reduction  in  the  external  costs  of 
accidents driven by the lives saved and injuries avoided, but also due to the mutual recognition of the 
mobile driving licences that leads to administrative cost savings and enforcement cost savings for 
Member  States  administrations  and  hassle  cost  savings  for  citizens  and  the  private  sector.  PO-A 
shows the lowest total benefits estimated at EUR 9,869.7 million relative to the baseline (expressed 
as present value over 2025-2050, in 2021 prices). PO-B shows significantly higher benefits, estimated 
at EUR 19,965.7 million, expressed as present value over 2025-2050 relative to the baseline. The 
main  differences  between  PO-A  and  PO-B  in  terms  of  cost  savings  are  related  to  the  medical 
screening for drivers, which will reduce the number of medical checks of elderly people, the removal 
of the staging requirement to obtain a licence of category CE or DE for professional drivers, but also 
due to the considerable reduction in the external costs of accidents. PO-C shows higher benefits than 
PO-B,  estimated  at  EUR  21,785.1  million  (expressed  as  present  value  over  2025-2050,  in  2021 
prices) relative to the baseline, mainly due to the higher reduction in the external costs of accidents 
brought about by the lives saved and injuries avoided. 

Overall, all policy options result in net benefits relative to the baseline. The net benefits are estimated 
at EUR 9,753.4 million in PO-A relative to the baseline, expressed as present value over 2025-2050, 
at EUR 18,658.2 to 19,101.6.1 million in PO-B and EUR 11,574.3 to 14,063.3 million in PO-C. The 
net benefits are highest in PO-B, followed by PO-C and PO-A. PO-C shows the lowest benefit to cost 
ratio (2.1 to 2.8), followed by PO-B (15.3 to 23.1) and PO-A (84.9).   

7.3  7.3 

Coherence 

Internal  coherence  assesses  how  various  elements  of  the  revised  Directive  function  together  to 
achieve the objectives. Although all three POs address the identified problems, they do so in different 

53 

 
  
 
ways, and with a different level of intervention. PO-A addresses the problems and objectives with a 
mix of policy options that are common also to the other two options. PO-B and PO-C require further 
harmonisation and thus ensure a higher degree of internal coherence than PO-A. Since the revision 
also deals with matters  related to the enforcement of sanctions (i.e. mutual recognition of driving 
disqualifications in PO-B and PO-C), particular care is taken not to exceed what is essential to achieve 
one of the main objectives of the initiative, which is to improve road safety. The legal examination 
referred to in part 3.1, identified Article 91(1) TFEU to be the correct legal basis for the adoption of 
such  measures.  Nevertheless,  as  the  mutual  recognition  of  decisions/judgments  are  principally 
covered by Title V of Part Three of the TFEU (judicial and police cooperation), these measures will 
need to be drawn up carefully to avoid elements that should be regulated under one of the legal bases 
provided therein. This is relevant for both options PO-B and PO-C. 

External coherence concentrates on the compliance of the initiative with national policies, other EU 
instruments  and  relevant  EU  policies,  as  well  as  international  obligations.  All  identified  policy 
options show strong links to several EU instruments. The vehicle categories for mopeds, motorcycles, 
tri-  and  quadri-motorcycles  are  defined  on  the  basis  of  the  type  approval  regulation  for  these 
vehicles185. The exchange  of information  related to  driving licences, including  for the EU mobile 
driving licence, have to be aligned with relevant rules on data protection. The introduction of the EU 
mobile driving licence relies on the eIDAS initiative whose legislative proposal186 is still discussed 
by the co-legislators and certain technical features are not yet consolidated in detail. Specific attention 
will be required to ensure the coherence between the initiatives on eIDAS and on driving licences, 
notably regarding the compatibility of the ISO/IEC 18013-5 standard and the relevant judicial and 
police rules for road traffic.  

The  compliance  with  the  UNECE  conventions  on  road  traffic  (Geneva  1949,  Vienna  1968)  will 
remain  in  place  in  all  policy  options.  Specific  measures  such  as  sub-categories  (e.g.  A2)  or 
equivalences will continue to be relevant only on the territory of the EU/EEA Member States. The 
EU mobile driving licence introduced by all policy options will be subject to this limitation and that 
is the reason why it will still be possible to carry a physical driving licence. In addition, measures in 
relation to road traffic offenses (PMc 4 in all policy options, PM 4 in PO-B and PM 5 in PO-C) will 
ensure  coherence  with  national  laws  relevant  to  that  matter.  The  mutual  recognition  of  driving 
disqualifications  of  foreign  drivers,  introduced  in  PO-B  and  PO-C,  is  designed  in  a  way  not  to 
interfere  with  national  legislations,  especially  as  regards  the  definition  and  classification  of  what 
constitutes an offence (irrespectively of their criminal or administrative nature), and the national rules 
of procedure (including enforcement) that govern criminal and administrative offenses.  

7.4  7.4 

Subsidiarity and proportionality 

The  intervention  at  EU  level  is  needed  to  facilitate  free  movement  through  harmonised  rules  on 
driving licences, as Member States on their own cannot ensure the seamless recognition of the right 
to drive provided by a driving licence issued by another Member State. Regarding road safety, the 
majority of Member States cannot contribute to the EU targets on road safety on their own, as the 
quality of the training and of the licensing systems of other Member States influences their policy 
intervention (e.g. cases of numerous tourists on the roads of France or Spain during the months of 
July  and  August).  Member  States  could  conclude  bilateral  and  multilateral  agreements,  but 
cooperation would remain fragmented as these agreements would not be harmonised and applicable 
elsewhere in the EU. A transparent, efficient, and coordinated approach with equal treatment of road 

185  Regulation (EU) No 168/2013 (OJ L 60, 2.3.013, p. 52) 
186  COM(2021) 281 final of 3.6.2021 (https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:52021PC0281) 

54 

 
                                                 
users  on  EU  roads  is  therefore  needed.  As  all  policy  options  ensure  a  harmonisation  of  the  legal 
framework, the requirement of subsidiarity is fulfilled.  

Possible issues related to subsidiarity are mainly related to the measures on the mutual recognition 
of  driving  disqualifications  (PM4  for  policy  option  PO-B  and  PM5  for  PO-C),  with  a  higher 
likelihood of possible subsidiarity issues for PM5  given the larger scope of this measure (i.e. the 
related offences include recidivism in addition to speeding and drink driving for PM4). 

The definition and effects of offenses are established by national road traffic rules, including recidivism 
(penalty points). The initiative does not aim at regulating these aspects at EU level. It will only provide a 
legal instrument to enable the mutual recognition of driving disqualifications resulting from speeding, drink 
driving (PM4, PM5) and penalty points (PM5). 

It is worth noting however, that since the decision to issue or withdraw a driving licence forms part 
of  a  Member  State’s  sovereignty,  it  is  not  possible  to  unilaterally  adopt  rules  on  the  mutual 
recognition of driving disqualification measures issued by other Member States. The recognition of 
driving disqualifications requires an agreement between the Member State that issued the decision 
and the Member State that executes it, which cannot be achieved only through national rules. In the 
absence of such an agreement, Member States can act only with an effect limited to their territory, in 
case  they  wish  to  restrict  the  validity  of  such  documents.  The  Union-wide  effects  of  a  driving 
disqualification will therefore always be dependent on the actions of the Member State that issued 
the  driving  licence,  but  which  without  an  EU  intervention  usually  does  not  have  the  necessary 
information, legal instruments, or incentive to act. 

Following the Court of Justice of the European Union’s interpretation of the Directive, even in cases 
where the disqualification was enacted by the Member State that issued the driving licence, if the 
offender changes the normal residence and he/she is issued a new driving licence, every Member 
State must accept it. This includes the place of their previous normal residence that decided on the 
disqualification. As this case law is underpinned by the principle of mutual recognition of driving 
licences, it can only be sufficiently addressed by EU legislation. 

From  a  legal  point  of  view,  the  only  viable  alternative  of  EU  action  would  be  bi-  or  multilateral 
treaties. However, experience shows that this alternative is only theoretical. There is only one such 
bilateral agreement in place (between Ireland and the United Kingdom). Several Conventions in the 
past (1964, 1976) tried to address the issue of driving disqualification in the framework of the Council 
of Europe. However, they were not ratified by enough Member States to be effective. 

Furthermore, the legal examination concluded that it is not possible to use in the same legislative 
instrument a dual legal basis, i.e. common transport policy legal basis together with the legal basis 
contained  within  Title  V  of  Part  Three  of  the  TFEU  (judicial  and  police  cooperation)  due  to  the 
Treaty-based  procedural  specificities  and  legal  effects  of  acts  based  on  Article  82  TFEU. 
Consequently, two separate legal acts on the two respective legal bases would be required in case the 
mutual  recognition  of  driving  disqualifications  was  to  be  ensured  for  administrative  and  criminal 
offenses alike.  

Finally, driving disqualifications can be covered under the transport legal basis in so far as the offence 
in question qualified as administrative by nature and would be disqualifying in both Member States, 
the one where it is committed and the one of issuance/residence (principle of ‘dual disqualification’). 
This  should  apply  to  penalty  points  as  well.  Therefore,  as  regards  penalty  points  the  measure  is 
designed in a way that it is not affected by the difference between road traffic rules across Member 
States. The principle is to extend the mutual recognition of driving disqualifications resulting from 
offenses of drink driving or speeding (PM4) to driving disqualifications resulting from an excessive 

55 

 
number of penalty points, in cases where such a sanction is already provided for by both Member 
States based on the penalty points issued for the conduct.  

Points  of  attention,  in  particular  not  to  interfere  with  the  national  constitutional  and  JHA187 
frameworks, have been identified and should be fully taken into account when offences fall under 
criminal law. However, it should be underlined that during the consultation activities, one Member 
State (Germany) expressed the view that such a measure would exceed the EU competence on police 
and judicial cooperation and may not be compatible with the Constitution of the Federal Republic of 
Germany.  

In addition, questions of subsidiarity  regarding other measures such as the assessment of medical 
fitness to drive (PM6 for policy option PO-B, PM7 for PO-C), rules on administrative validity (PMc 
11 for all policy options) and requirements related to theminimum age for different licence categories 
(PM 1 for policy options PO-B and PO-C) are not expected because these aspects are already covered 
to a certain extent by Articles 4 and 7 of the current Directive: 

  Regarding medical fitness, the relevant measures (PM 6 for PO-B and PM 7 for PO-C) will slightly 
expand the scope of the Directive with the introduction of a mandatory screening for category A and B 
licences. However, it should be noted that similar requirements already exist in the Directive, notably for 
categories C (trucks) and D (buses) where medical assessment is required at renewal and replacement of 
the licences. 

It should also be added that the principle of mutual recognition of driving licences is anchored on 
the principle that drivers from different Members States have an equivalent level of aptitude to 
drive  both  in  terms  knowledge,  training  but  also  of  physical  health.  Allowing  physically  unfit 
drivers to exchange their driving licenses in Members States with a more refined health screening 
system could put at stake the trust of the whole EU system of exchange of driving licences.  It 
could also affect road safety, because it would allow drivers with different levels of fitness to drive 
on EU roads. 

Finally, it can also be reported that no issue has been raised on the basis of Article 168 TFEU188 
regarding the feasibility of such measures. Indeed, measures which aim to harmonize the medical 
fitness assessment of drivers can be considered an important element of the mutual recognition of 
driving licenses and, while medical in nature, they are not related to measures of public safety as 
defined in Article 168 TFEU. 

  Regarding the administrative validity, it should also be noted that the planned new duration of validity 
(15 years) is already in place in 12 Member States (AT, CY, CZ, DE, DK, FI, FR, EL, LU, PL, PT, SK) 
and no opposition has been expressed during the consultation activities when considering this specific 
measure (PMc 11). Allowing to issue driving licences for temporary foreign workers for the duration of 
their residence permit should be considered as an optional and temporary derogation, which Member 
States decide upon.  

  Regarding minimum age, it should first be noted that the measure on reducing minimum age(s) required 
for obtaining a driving licence was discarded. The only measure retained with an impact on age is PM1, 
which sets rules on accompanied driving for drivers between 17 and 18 years old, and it applies after 
they pass the driving test for driving licences B and C. Subsidiarity is therefore respected because if 
Member States were allowed to create divergent national regimes this would constitute a discrimination 

187  Justice and Home Affairs 
188  Art. 168 TFEU - (ex Article 152 TEC) (lexparency.org) 

56 

 
                                                 
between those young people that would have the possibility to drive before reaching majority, and those 
who would not. This argument is particularly relevant for category C driving licences, because this would 
mean that candidate drivers from Members States that would not accept accompanied driving before 18 
years, would only start their professional training one year later than candidates from Member States 
with those systems in place. In addition, this could also change the level playing field between Member 
States in tackling driver shortage, because those Member States having a system of accompanied driving 
will have prepared professional drivers sooner than those who do not. Finally, besides improving the 
quality of training, the goal of accompanied driving is the reduction of fatalities in which young drivers 
are involved.  

In relation to proportionality, the proposed revision aims to improve road safety and to facilitate the 
free movement of persons. PO-A contributes to this objective by updating the existing provisions of 
the  Directive,  taking  into  account  technological,  scientific  and  societal  evolutions.  The  measures 
proposed under PO-A are therefore considered to be proportionate in view of the objectives of the 
revision. 

PO-B in addition reinforces the EU intervention to ensure that drivers on EU roads are fit to drive 
and  resolves  some  specific  issues  of  free  movement.  The  measures  proposed  under  PO-B  are 
proportionate in view of the objectives of the revision. 

PO-C builds on PO-B but reinforces it, with the intervention regarding the measures that affect third 
country  drivers,  dangerous  behaviour  and  persons  physically  or  mentally  unfit  to  drive.  The 
stakeholders’ views are divided, and while some Member States consider that the rules on fitness to 
drive and on driving licences issued by third countries are sufficient, others believe that there is a 
need for further action.  

Regarding medical fitness, PO-A takes into account the evolution of health care and technologies 
(PMc 5), to clarify the use of technologies to offset medical unfitness to drive (PMc 6) and to facilitate 
the exchange of information on this specific topic between authorities (PMc 7). It does not change 
the general approach to medical fitness to drive established by the Directive. The policy options PO-
B and PO-C however modify the way in which the medical fitness to drive of drivers and applicants 
is  verified.  Both  PM  6  and  PM  7  introduce  a  system  of  screening,  considering  the  best  practices 
notably implemented in Sweden and shifting the age-focused approach of the current Directive to a 
system  allowing  a  progressive  identification  of  a  driver’s  or  applicant’s  fitness  to  drive.  PM  7 
includes a more strict screening resulting in higher adjustment costs for drivers and applicants but 
also in a higher rate of detection of cases of unfitness to drive. Finally, PM 10 simply provides for 
additional  freedom  of  movement  with  the  mutual  recognition  of  medical  fitness  assessments, 
considering that the systems implemented in all Member States will be sufficiently aligned for such 
a recognition.  

Considering the foresight megatrend “Accelerating technological change and hyperconnectivity”, 
the need to hold a driving licence is expected to become obsolete when full automation will be in 
place because  the driver’s  role will  become  extremely limited or marginal.  However, introducing 
consolidated rules on driving rights also for highly automated vehicles would result in a risk to have 
them changed in the foreseeable future, either because of the lessons learnt in the field or to become 
interoperable several times with international partners. Such an approach would not be proportionate 
in the absence of a common and mature approach on automated vehicles at international level and it 
would create legal uncertainty for the market. Each policy option includes the update of standards on 
skills and knowledge applicable to drivers (PMc1) which provide sufficient flexibility to adapt the 
rules to automated vehicles for the cases where the driver may be requested or may decide to take 
back the control (levels 3 and 4 of automation).  

57 

 
8 

8  PREFERRED OPTION 

8.1  8.1 

Identification of the preferred policy option and stakeholder views  

Regarding  effectiveness,  the  impact  assessment  concludes  that  all  options  will  contribute  to  the 
general objectives of the initiative by 1) facilitating the free movement of all EU residents and by 2) 
reducing the number of road traffic accidents, notably those involving novice drivers.  

When addressing specific objective 1 (Improve driving skills, knowledge and experience and reduce and 
punish dangerous behaviour), all options are expected to reduce road fatalities. However, PO-B and PO-C 
are expected to be more effective than PO-A, due to the expected reduction of road accidents for novice 
drivers (the introduction of a probation period and stricter rules for novice drivers).  

In the OPC, 5,787 out of 7,532 respondents stated that improving the provisions of the Directive on 
the standards on drivers’ skills and knowledge is extremely/very important to meet EU road safety 
targets and to remove the obstacles to free movement. This was reinforced during the workshops, 
where  it  was  highlighted  that  sustainable  mobility  and  multimodality  should  be  promoted  during 
training programmes (Italy, ECF). Also, a majority of respondents (53%, 5,073 out of 7,532) stated 
that EU rules on driving skills affecting the emission and energy consumption of vehicles is relevant 
for the EU objective of climate neutrality by 2050.  

Both PO-B and PO-C are expected to address dangerous behaviour on the road while driving abroad in the 
EU, by introducing the mutual recognition of driving disqualifications. In terms of this specific objective, 
PO-C is expected to be the most effective, but only marginally, which is due to the fact that it is the only 
option that introduces rules on penalty points for drivers committing offenses abroad. 

A large majority of respondents to the OPC (68%, 5,146 out of 7,532) stated that it is very/important 
that  the  scope  of  the  Directive  is  expanded  to  include  rules  on  the  mutual  recognition  of  driving 
disqualifications. Most stakeholders189 supported the mutual recognition of driving disqualifications 
during the workshop and the targeted interviews. However, NL raised some legal concerns, while 
DE was the only stakeholder to firmly disagree with the mutual recognition. 

Overall, many stakeholders were supportive of the mutual recognition of driving disqualifications, 
especially when it comes to offenses related to speeding and drink/drunk driving. This was confirmed 
in  the OPC,  where  about  6,106 (81%) and  4,966 (66%) out of 7,532  respondents,  considered the 
mutual recognition of driving disqualifications resulting from driving under the influence of alcohol 
or  of  drugs  and  from  speeding  as  very/important  for  the  revision  of  the  Directive  respectively. 
Specificially,  when  asked  which  offences  should  be  mutually  recognised  in  the  EU,  87%  of 
respondents to the OPC (6,586 out of 7,532) chose driving under the influence of alcohol and drugs 
and 46% (3,470 out of 7,532) selected speeding. In the targeted interviews, the ETSC, as well as 
ACEM  and  the  DKU  expressed  support  for  the  mutual  recognition  of  driving  disqualifications 
resulting  from  speeding,  drink/drunk  driving.  SE,  SI  and  BE  were  also  supportive,  despite 
acknowledging the difficulties in finding an agreement with other Member States and with the actual 
implementation.  

Concerning specific objective 2 (Ensure adequate physical and mental fitness of drivers across the 
EU),  the  effects  of  PO-A  are  expected  to  be  only  marginally  positive.  Both  PO-B  and  PO-C  are 
expected  to  improve  road  safety  more  than  PO-A  due  to  the  screening  of  medical  fitness.  PO-B 
contains the mandatory screening of medical fitness at renewal, based on a self-assessment, and more 

189  FR, HU, SE, SI, BE, NL, ETSC, FEVR and CEETAR. 

58 

 
                                                 
frequent  medical  screening  for  drivers  aged  70  years  or  more.  PO-C  is  more  ambitious  –  and  it 
includes  a  more  advanced  medical  screening  requirement  and  frequent  verifications  extended  to 
drivers above the age of 65, which will be mandatory every 5 years. Again, PO-C is most effective 
when achieving this objective. 

The  survey  showed  that  70%  of  the  non-governmental  organisations’  respondents  (16  out  of  23) 
considered that requiring medical fitness to be screened at driving licence renewal for categories A 
and B would have a positive impact on road safety. Non-governmental organisations were divided 
on the impact of this measure on the free movement of drivers: while 35% of the respondents (8 out 
of 23) believe it will have no impact on the free movement of drivers, 21% (5 out of 23) believe it 
would increase free movement and 9% (2 out of 23) believe it would decrease free movement.  

On the introduction of guidelines/recommendations for a standardised medical screening process for 
B licences, several stakeholders would support it190. DE, on the other hand, would oppose it. In the 
survey, a majority of respondents from national  authorities (13/21) expected a positive impact on 
road safety from the provision of guidelines/recommendations for a standardised medical screening 
process for B licences. In the survey, 78% of the non-governmental organisation respondents (18/23) 
considered that providing guidelines/recommendations for a standardised medical screening process 
for  B  licences  would  have  a  positive  impact  on  road  safety  (small  positive  impact:  10/23;  large 
positive impact: 8/23). The establishment of a platform for the sharing of best practices on medical 
check procedures adopted in EU Member States was supported by most interviewed stakeholders191. 
In the survey among national authorities, the measure was expected to have positive impacts on road 
safety by a majority of respondents (13/21). In the survey among non-governmental organisations, 
70% of respondents (16/23) found that establishing a platform for efficient sharing of best practices 
on medical checks procedures would have a positive impact on road safety.  

All options are also designed to remove unnecessary barriers for applicants and holders of driving 
licences (specific objective 3). The main impact here will be brought by the introduction of the mobile 
driving licence. PO-B and PO-C are expected to perform better to achieve this objective than PO-A. 
PO-C is expected to be marginally the most effective in addressing this objective, since it will in 
addition  remove or  reduce administrative barriers affecting persons which are not  covered by the 
other options, such as former holders of licences issued in third countries who already established 
their residence in the EU.  

Most  interviewed  Member  States192,  as  well  as  other  stakeholders  (ETSC,  ACEM,  and  DKU) 
strongly  supported  the  establishment  of  the  mutual  recognition  of  mobile  driving  licences. 
Interviewed Member States also called for the interoperability of mobile driving licences, based on 
ISO standards.  

Regarding the costs, the major cost element of the policy options are the adjustment costs for citizens 
related to the rules on medical screening, which are incurred only in PO-B and PO-C. PO-A shows 
lower costs than PO-B as it does not cover the rules on simple medical screening and the mutual 
recognition of driving disqualifications, as it is the case for PO-B. PO-C shows the highest total costs. 
Again, the difference in costs between PO-B and PO-C is driven by the rules on medical screening. 

Regarding efficiency, all policy options result in significant net benefits relative to the baseline, with 
the  net  benefit  being  the  highest  in  PO-B,  followed  by  PO-C  and  PO-A.  PO-C  shows  the  lowest 

190  FIA, ETSC, BG and DKU. 
191  BG, DE, FI, SE, FIA, ACEM and DKU. 
192  BE, BG, DE, NL SE and SI. 

59 

 
                                                 
benefit to cost ratio, followed by PO-B and PO-A. The benefit to cost ratio is estimated at 84.9 for 
PO-A, 15.3 to 23.1 for PO-B and 2.1 to 2.8 for PO-C. In terms of efficiency, therefore PO-A gives 
the best results. This is mainly due to the absence of costs related to the medical screening in PO-A 
relative to PO-B and PO-C. Also, the difference in costs between PO-B and PO-C is driven by the 
rules on medical screening, with PO-C showing the highest costs. 

On  the  basis  of  the  assessment  of  effectiveness  of  the  three  options  in  relation  to  the  specific 
objectives  of  the  initiative,  PO-A  is  the  least  performing  option  and  PO-B  and  PO-C  perform 
similarly, with a marginal advantage for PO-C in the overall assessment of the effectiveness due to 
the more demanding medical screening requirement and due to reducing administrative barriers for 
former holders of licences issued in third countries having their residence in the EU. As to efficiency, 
the best performing option is PO-A followed by PO-B, with PO-C lagging far behind. PO-A performs 
most efficiently as it does not provide any requirement regarding medical screening, but this also 
means that it is expected to be less ambitious regarding the general objective of increasing road safety.  

Concerning internal coherence, PO-A remains coherent with relevant EU legislation while both PO-
B and PO-C were assessed in view of possible issues regarding the legal base and  the delineation 
with  national  legislation  on  recognising  and  enforcing  decisions  related  to  road  traffic  offences, 
which will both have to be considered carefully. In addition, all policy options bear the same risk that 
the eIDAS rules do not allow for interoperability of mobile driving licences issued in the EU with 
the  ISO/IEC  18013-5  standard.  Concerning  external  coherence,  PO-A  remains  coherent  with 
national  and  other  international  legislations.  PO-B  and  especially  PO-C  might  lead  to  issues  of 
external  coherence, in  particular by interfering too  much with  criminal  law, in  particular national 
legislation  on  recognising  and  enforcing  decisions  related  to  road  traffic  offences.  In  terms  of 
subsidiarity, all options fulfil this principle, and they would all bring about the harmonisation of the 
legal framework, albeit at different levels of ambition. With respect to the proportionality, PO-A 
and  PO-B  will  both  achieve  the  objectives  in  a  coherent  and  effective  way,  while  leaving  the 
necessary scope for national decision. PO-C may however result in issues of proportionality, due to 
the high level of policy intervention regarding the fight against dangerous behaviour of drivers (PO5) 
and unfitness to drive (PO7) resulting in significant changes to the existing approaches in Member 
States.  

Overall, considering the assessment of effectiveness, efficiency, and coherence of the three options, 
and given that all three options are proportionate and comply with subsidiarity, the analysis points 
at  PO-B  as  the  preferred  policy  option,  since  it  brings  the  best  balance  between  the  objectives 
which must be achieved (increasing road safety and facilitating the free movement of persons) and 
costs and benefits incurred.  

Stakeholders widely supported the measures common to all policy options, such as on the update of 
standards on skills and knowledge and those on medical fitness, the harmonisation of the administrative 
validity of category A and B licences, and the introduction of a mobile driving licence, with some 
different views expressed on the technical and administrative solutions. 

In  addition  to  these  measures,  measures  on  training  and  probation  periods  in  PO-B  have  been  widely 
supported by administrations and stakeholders although with some potential concerns expressed by certain 
Member States193.  

In the OPC, about 66% of respondents agreed that it is very/important to extend the scope of the 
Directive by introducing rules on training and probation periods (including accompanied driving). 

193  SE questioned the need for harmonisation, DE and FI were opposed to certain restrictions 

60 

 
                                                 
The lack of harmonisation in  this area was further emphasised in  the workshops (CERT, ETSC). 
Most interviewed stakeholders (FI, FIA, ETSC, ACEM, and DKU) agreed that rules on training need 
to  be  extended  to  cater  for  e.g.,  different  weather  and  traffic  conditions.  In  the  OPC,  57%  of 
respondents (4,998 out of 7,532) considered important introducing a minimum number of kilometres 
or hours of training required to pass a driving test in the revision of the Directive. According to a 
majority of survey respondents from national authorities (17 out of 22), providing further rules on 
training would have a generally positive impact on road safety.  

Also, EU level recommendations on the content of drivers’ training programmes would be welcomed 
by  most  interviewed  stakeholders  (DE,  FIA,  ETSC,  ACEM  and  SE).  The  introduction  of 
recommendations on the content of drivers’ training programme was considered to have a positive 
impact on road safety by a majority of survey respondents from national authorities (15/22).  

The introduction of common minimum standards of a mandatory probation period was supported by 
a majority of respondents to the OPC (57%, 4,297 out of 7,532). In the targeted survey, the impact 
of establishing a probation period was assessed as generally positive for road safety by a majority of 
respondents from national authorities (15/24).  

Regarding  the  increase  of  maximum  mass  for  electric  vehicles,  the  measure  has  been  generally 
welcomed, albeit some stakeholders would prefer to have it in place for all vehicles (for example 
users  of  camper  vans  have  expressed  the  need  for  an  increase  of  maximum  mass  but  without 
restrictions  related  to  the  type  of  propulsion).  A  road  safety  organisation194 opposed  the  measure 
considering  the  likely  degradation  of  road  safety  while  four  Member  States195 asked  to  apply  the 
extending measure to all vehicles. Finally, most Member States acknowledged the issue related to 
licences issued by third countries, but they were of diverging views regarding the proportionality of 
such a measure. 

PO-B is expected to strike the right balance regarding mutual recognition of driver disqualifications 
for severe offences (PM 4), which was supported by many stakeholders in the public consultation 
(4,731 respondents out of 7,532, or 62%) as well as stakeholders during the workshop196, with some 
raising legal concerns197. It also introduces basic medical fitness screening (PM6) which should in 
stakeholder’s view bring positive impacts on road safety, despite the expected increase in costs for 
businesses and drivers, while PO-C with more stringent rules on medical fitness screening appears 
more costly and more intervening, hence less acceptable to Member States.   

On the basis of what precedes and the analysis above it can be concluded that PO-B is the preferred 
policy option.  

8.2  8.2 

REFIT (simplification and improved efficiency) 

This initiative is part of the Commission Work Programme 2022 under Annex II (REFIT initiatives), 
under the heading ‘A New Push for European Democracy’198. The initiative has an important REFIT 
dimension in terms of simplification and alignment of the procedures that Member States apply to 
driving licences. An important cost burden resulting from the Directive on driving licences are the 
issuance procedures and the production of the physical driving licence because of the large number 
of EU residents concerned. An important part of simplification and related burden reduction will be 

194  ETSC 
195  DE, BG, FR and FI 
196  FEVR, ETSC, CEETAR, FR, NL, SI, SE, BE 
197  NL, DE 
198  COM(2021) 645 final  

61 

 
                                                 
the introduction of the EU mobile driving licence. Specifically, it will be easier to obtain, replace, 
renew or exchange a mobile driving licence as it will be possible to perform the complete procedure 
on-line. In addition, the harmonisation of the administrative validity of driving licences for group 1 
drivers (category A and B licences) will also result in less interaction with the administration because 
of the less frequent need for renewal of the driving licence (every 15 years instead of every 10 years 
for the Member State currently applying this rule). 

8.3  8.3 

Application of the ‘one in, one out’ approach  

PO-B is expected to lead to significant administrative cost savings for road transport operators due 
to the removal of the requirement to hold a licence of category C or D to obtain a licence of category 
CE  or  DE  (PM8).  As  explained  in  section  6.1.1,  the  annual  average  reduction  in  the  number  of 
theoretical and practical tests for 2025-2050 is estimated at 510,474 relative to the baseline and the 
annual average cost savings for 2025-2050 at EUR 48.5 million199, which implies an average cost per 
theoretical and practical test for the C and D category licence of EUR 95. 

PO-B is also expected to lead to administrative cost savings for holders of a Code 78 licence (PM2c). 
The annual average reduction in the number of practical tests for 2025-2050 has been estimated at 
1,184  relative  to  the  baseline  and  the  annual  average  decrease  in  the  administrative  costs  for 
2025-2050 at EUR 0.1 million, which implies an average cost per practical test of EUR 92.  

Overall,  PO-B  is  estimated  to  lead  to  administrative  cost  savings  for  citizens  and  businesses, 
estimated at EUR 48.6 million per year.  

9 

9  HOW WILL ACTUAL IMPACT BE MONITORED AND EVALUATED? 

The revision of the Directive on driving licences will result in the adoption of a fourth act addressing 
this topic. The first three Directives have already contributed significantly to an improvement of road 
safety  and  of  the  free  movement  of  people,  resulting  in  drivers  who  are  more  skilled  and 
knowledgeable and more fit to drive. In addition, the impunity of traffic offenders has been reduced 
with  the introduction of a single driving licence in the EU and  the  establishment of the RESPER 
network. At the same time, rules on issuance and exchange of EU driving licences allow most drivers 
to travel or change residence in the EU without facing significant obstacles or difficulties. 

Most  likely  the  changes  to  be  proposed  will  not  have  the  same  impact  on  the  ground  as  the  low 
hanging fruits that have already been reaped. When it comes to road safety, however, incremental 
improvements are important as each life saved counts on the way to achieve “Vision Zero” (close to 
zero fatalities on the EU roads by 2050) – provided that the measures used to achieve this aim are not 
disproportionate. The preferred policy option is  expected to  lead to  1,153 lives saved and 11,020 
injuries avoided over the 2025-2050 period relative to the baseline.  

Since the general objective is the improvement of road safety, the core indicator to measure success 
of the initiative would be a reduction in the number of road fatalities and the number of seriously 
injured persons in accidents for which the driver is considered one of the causes. For that purpose, 
the number of accidents will be considered in total and when certain conditions are met (e.g. the ones 
involving only one vehicle or those where the driver was a novice or physically/mentally unfit to 
drive). The indicator will have to also consider overall road safety developments and the evolution 

199  Both the annual reduction in the number of tests and the annual costs savings are calculated as simple averages over 2025-2050 

for the purpose of ‘one in, one out’. 

62 

 
                                                 
of road traffic and of the number of driving licences in each Member State (to take account of other 
possible factors).  

In  relation  to  the  second  general  objective  of  facilitating  the  free  movement  of  persons,  the  core 
indicator to measure success of the initiative would be a reduction in the number of complaints and 
court cases in relation to the driving licences’ procedures.  

The indicators  related to  both  objectives  will continue  however to  be  relatively  difficult to  assess 
because of the multiple underlying causes of accidents, the unavailability of data and the low number 
of complaints and court cases in relation to driving licences’ procedures. 

For SO1, the success will be measured by the fact that standards on skills, knowledge, and probation 
periods  to  be  met  for  the  first  issuance  of  a  driving  licence  are  harmonised,  and  that  dangerous 
behaviour is sanctioned irrespectively of the residence of the offender. For SO2, the share of drivers 
regularly medically screened, depending on health status and age, will be a measure of success. For 
SO3,  the  number  of  MS  issuing  mobile  driving  licences  and/or  recognising  EU  mobile  driving 
licences will be a measure of success, as well as a low number of complaints and court cases where 
normal residence is an obstacle to the recognition of existing driving rights.  

The Commission will monitor the implementation and effectiveness of this initiative through several 
actions  and  a  set  of  core  indicators  that  will  measure  progress  towards  achieving  the  operational 
objectives.  Five  years  after  the  deadline  for  transposition  of  the  legislative  act,  the  Commission 
services should carry out an evaluation to verify to what extent the objectives of the initiative have 
been reached. 

Established monitoring instruments (e.g. the CARE database) will be used to monitor the correlation 
between road accidents and driving licences. The reporting will include information on the number 
of accidents with injuries and/or fatalities as well as on the drivers involved such as their age, the 
validity and issuing date of their driving licences and results of their drug/alcohol tests. In order to 
allow, to the maximum extent possible, to separate the effects of the revised Directive from other 
factors, statistics on the number of driving licences issued will be retrieved from Member States. It 
should allow to assess the relative evolution of road safety for the main groups of drivers affected by 
the revision (e.g. novice drivers, drivers will health conditions).   

Statistics will also continue to be produced by the Commission regarding the use of the RESPER 
network for the exchange of information on driving licences, established under Article 15 of Directive 
2006/126/EC. The Commission may also explore the possibility to complement this information with 
statistics  produced  by  EUCARIS,  the  application  used  by  several  Member  States  to  connect  to 
RESPER.  

With  respect  to  the  interoperability  of  the  EU  mobile  driving  licence,  a  dedicated  working  group 
under the Committee established under Article 9 of the Directive will monitor the progress with the 
objective to identify and solve potential issues.  

The Commission will also invite Member States to share statistics acquired from national registries, 
as it has been done in the frame of the support study for this impact assessment, in particular on the 
number of licences issued per categories, per gender and per age group. 

63 

 
 
 
ANNEX 1: PROCEDURAL INFORMATION 

1. LEAD DG, DECIDE PLANNING/CWP REFERENCES 

The lead DG is DG MOVE, Unit C2: Road Safety 

DECIDE reference number: PLAN/2021/10346 

Item 25 in Annex II (REFIT initiatives) to the Commission Work Programme 2022 

2. ORGANISATION AND TIMING 

The impact assessment follows the ex-post evaluation of Directive 2006/126/EC on driving licences 
published  in  2021.  The  impact  assessment  started  in  2021,  with  the  publication  of  the  inception 
impact assessment on 23 April 2021200.  

The impact assessment on a possible review of the Directive on driving licences was coordinated by 
an Inter-Service Steering Group (ISSG). The Commission Services participating in the ISSG were: 
Secretariat-General  (SG),  Legal  Service  (LS),  DG  Communications  Networks,  Content  and 
Technology  (CNECT),  DG  Justice  and  Consumers  (JUST),  DG  Migration  and  Home  Affairs 
(HOME),  DG  Climate  Action  (CLIMA),  DG  Environment  (ENV),  DG  for  Employment,  Social 
Affairs  and  Inclusion  (EMPL),  DG  Health  and  Food  Safety  (SANTE)  and  DG  Industry, 
Entrepreneurship and SMEs (GROW). The Inter-Service Steering Group met altogether six times: 
on 31 March 2021, 1 June 2021, 22 July 2021, 24 June 2022, 6 September 2022 and 6 October 2022. 
It  was  consulted  throughout  the  different  steps  of  the  impact  assessment  process:  notably  on  all 
stakeholder consultation materials and deliverables from the external contractor and on the draft Staff 
Working Document.  

3. CONSULTATION OF THE RSB 

The  Impact  Assessment  received  a  positive  opinion  from  the  Regulatory  Scrutiny  Board  on  18 
November 2022 which made the following main recommendations for improvements:  

RSB comments 

Modification of the IA report 

(1)  The  presentation  of  the  measures  and 
their implications should be improved. The 
option  description  should  be  detailed 
enough to allow a better understanding of 
the  functionality  of  the  measures  and  any 
trade-offs between different objectives. 

In  Section  5.2.3,  the  description  of  the 
measures PMc 4, PMc 8, PM 2, PM 3, PM 9, 
PM 12 and PM 14 has been improved. A new 
section  5.2.4  has  been  introduced  to  discuss 
the  trade-offs  between  the  measures  PMc2, 
PMc 3, PM1 and PM 11.  

(2)  The  report  should  better  explain  the 
feasibility  of  certain  options  as  regards 
subsidiarity,  for  instance,  on  the  mutual 
recognition  of  driving  disqualification.  It 
should  explicitly  present  any  subsidiarity 

Section  7.4  has  been  updated  to  present  the 
subsidiarity  issues  related  to  the  mutual 
recognition  of  driving  disqualifications, 
including  with  reference  to  the  views  of 
Member  States.  Additional  information  has 

200  https://ec.europa.eu/info/law/better-regulation/have-your-say/initiatives/12978-Revision-of-the-Directive-on-Driving-

Licences_en  

64 

 
                                                 
issues  and  refer  to  the  views  of  Member 
States on the measures considered. 

also  been  introduced  regarding  the  measures 
on minimum age and medical fitness. 

(3)  The  report  should  better  justify  the 
choice  of  the  preferred  option.  It  should 
provide a more transparent comparison of 
terms  of 
options, 
effectiveness and efficiency. 

in  particular 

in 

(4)  The  report  should  further  clarify  the 
impact analysis. It should be more explicit 
about the costs related to medical screening 
and  explain  whether  these  are  (partially) 
covered  by  medical  insurance  schemes  in 
the  Member  States.  It  should  also  more 
clearly 
the 
administrative  and  adjustment  costs,  in 
particular in case of the costs for citizens. 

distinguish 

between 

Section  8.1  has  been  reinforced  to  better 
present  the  reasons  for  the  choice  of  the 
preferred option. 

In  section  6.1,  the  description  of  economic 
impacts  for  PMc  1  (new  standards  on  skills 
and  knowledge)  and  PM5/6  (medical  fitness 
screening  and  assessment)  has  been  updated 
accordingly. It has also been clarified that the 
costs  for  citizens  associated  to  PMc  1  are 
adjustment costs.  

4. EVIDENCE, SOURCES AND QUALITY 

The impact assessment is based on several sources, using both quantitative and qualitative data. This 
includes: 

•  Ex-post evaluation of Directive 2006/126/EC on driving licences (SWD(2022) 17 final) 

•  Stakeholder consultation activities (see Annex 2) 

•  External support study carried out by an independent consortium (lead by COWI)  

•  Commission experience in monitoring and implementing the Directive  

•  Community database on road accidents (CARE) 

65 

 
 
 
ANNEX 2: STAKEHOLDER CONSULTATION (SYNOPSIS REPORT) 

This  annex  provides  a  summary  of  the  outcomes  of  the  consultation  activities  carried  out  for  the 
review of the DL Directive, including in the context of the external support study. It notes the range 
of stakeholders consulted, describes the main consultation activities, and provides a succinct analysis 
of their views and the main issues they raised. The full analysis of the consultation results is presented 
in the stakeholder consultation report annexed to the support study. 

The objectives of the consultation activities were the following: 

(1) 

to collect information and opinions of stakeholders on the key problems and associated 
drivers, the definition of relevant policy objectives linked to those problems, and the 
identification, definition and screening of policy measures that could be considered in 
this Impact Assessment 

(2) 

to  gather  information  and  opinions  on  the  likely  impacts  of  policy  measures  and 
options. 

1. OVERVIEW OF CONSULTATION ACTIVITIES 

Consultation  activities  have  taken  place  in  2021  and  2022,  from  the  publication  of  the  Inception 
Impact Assessment (IIA) in May 2021, to the Open Public Consultation that closed in May 2022. 

As part of the initial feedback mechanism, interested parties had the possibility to provide feedback 
on the Inception Impact Assessment from 23 April to 21 May 2021. 

Subsequently, the following targeted consultation activities were carried out: 

(1) 

(2) 

(3) 

Two rounds of interviews were held; 
(a) 
(b) 

Exploratory interviews during the inception phase (Q1 and Q2 2022) 
In-depth interviews to plug information gaps and assess the expected impacts 
of policy measures (Q2 and Q3 2021). 

A survey to substantiate the problem analysis (Q2 2022).  
A survey to assess the impact of policy measures (Q2 and Q3 2022). 

Two rounds of surveys were carried out; 
(a) 
(b) 
Three expert workshops were held; 
(a) 
(b) 
(c) 

On training, testing and vehicle categories, on 22 March 2022.  
On issuance and mutual recognition of driving licences on 22 April 22. 
Consequences of road traffic offences and medical fitness on 19 May 2022. 

Finally,  an  open  public  consultation  was  accessible  on  the  website  “Have  your  Say”  from  25 
February to 20 May 2022. In total, 7,532 responses were received from different stakeholders. Some 
stakeholders also provided position papers together with their responses to the OPC. 58 additional 
written inputs including position papers were submitted together with the OPC responses. It should 
be  noted  that,  given  the  number  of  responses  and  the  method  used,  this  consultation  is  not  a 
representative survey nor is it analysed as such. The views of the respondents are presented hereafter 
objectively, without any inference as to what any majority or minority of citizens may think of each 
topic. 

66 

 
 
2. STAKEHOLDER GROUPS CONSULTED 

This section provides a short overview of the main types of stakeholders identified and targeted as 
part of the targeted consultation. 

Inception Impact Assessment  

The IIA was open to the general public and 2,213 responses have been received. Various stakeholders 
participated in the consultation: academic and research institutions, business associations, company 
and  business  organisations,  consumer  organisations,  EU  and  non-EU  citizens,  environmental 
organisations, non-governmental organisations, public authorities, trade unions and other interested 
stakeholders.  

The feedback has been largely focused on the increase of the maximum mass of vehicles that can be 
driven with a licence of category B (see below). The other feedback has been taken into account and 
addressed in the following consultation activities, for example in relation to mobile driving licences, 
optional equivalences, normal residence and driving disqualifications. 

Open Public Consultation (OPC) 

The  OPC  was  open  to  the  general  public  and  7,532  opinions  have  been  expressed.  Various 
stakeholders  participated  in  the  consultation:  academic  and  research  institutions,  business 
associations, company and business organisations, consumer organisations, EU and non-EU citizens, 
environmental organisations, non-governmental organisations, public authorities, trade unions and 
other interested stakeholders.  

Targeted survey 

The targeted survey has been shared with public authorities in Member States and non-governmental 
organisations,  driving  schools  and  driving  school  associations,  road  safety  organisations,  road 
transport association and/or their members, road users and road users' associations (citizen, drivers 
motorcyclists,  caravan),  industry/business  associations  and/or  their  members,  associations  for 
persons with disabilities, trade unions, international bodies (road safety), car insurance associations, 
digital service providers, data protection authorities and associations.  

Targeted interviews 

During in-depth interviews we focused on the following target groups: public authorities in Member 
States,  automotive  and  motorcycle  federations,  drivers'  associations,  driving  school  associations, 
European  transport  workers  association,  international  road  transport  association,  national  driving 
licence  authorities,  road  safety  and  road  users'  association,  vehicle  manufacturer  associations, 
transport safety disability association, driving school associations. 

Workshops 

Three  workshops  have  been  held  to  discuss  with  stakeholders  and  national  administrations  the 
following topics: 

1.  Training, testing and vehicles' categories - 22 March 2022 
2.  Issuance and mutual recognition of driving licences - 22 April 2022 
3.  Consequences of road traffic offences and medical fitness - 19 May 2022 

67 

 
The workshops have been announced publicly with a call for expression of interests to participate 
published on 8 February 2022 on the DG MOVE website201. All entities having expressed an interest 
have  been  invited  to  the  workshops,  except  14  driving  schools  established  in  Ireland  to  ensure  a 
balance representativeness of the audience202.  

The  following  stakeholders'  groups  have  been  invited:  academic  and  research  institutions, 
transport-related 
organisations, 
non-governmental  organisations,  road  safety  advocates,  public  authorities,  trade  unions  and  other 
interested stakeholders. 

environmental 

organisations, 

associations, 

consumer 

The participation to all the consultation activities is presented in the table below.  

Stakeholder type 

Academia 

Business associations 

EU citizens 

Non-EU citizens 

NGOs 

Public authorities 

Trade unions 

Other 

Total 

Interviews 

Survey 

IIA  Workshop  OPC  Total 

0 

5 

0 

0 

9 

11 

1 

0 

26 

0 

14 

0 

0 

17 

51 

0 

2 

84 

2 

44 

2037 

36 

13 

5 

3 

27 

7 

82 

0 

0 

9 

206 

7 

0 

2 

2 

178 

197 

7024  7024 

157 

157 

47 

33 

3 

73 

95 

4 

88 

90 

2213 

311 

7532  7642 

3. FEEDBACK RECEIVED ON PROBLEM DEFINITION 

The excessive number of deaths and serious injuries on EU roads 

According to DE, FI, SI, SE and FR their national rules are generally satisfactory and sufficient to 
deliver on the road safety targets established at the EU level.  

Nevertheless,  DE,  BG,  NL,  BE,  SE  and  FR  called  for  the  updating  of  standards  on  physical  and 
mental  fitness.  Only  FI  considered  the  EU  standards  as  adequate.NL  identified  some  room  for 
improvement in its national rules on training, examination and provisional licence system. 

In the open public consultation, 70% (5,319 out of 7,532 respondents) and 63% (4,732 out of 7,532 
respondents),  respectively,  evaluated  the  rules  on  drivers’  skills,  knowledge,  and  experience  and 
drivers’  physical  and  mental  fitness  to  be  adequate/very  adequate.  55%  (3,313  out  of  7,532 
respondents)  also  believed  the  EU  rules  on  drivers’  behaviour  on  the  road  to  be  adequate/very 
adequate. Stakeholders were more divided on the adequacy of the rules to fight unlicensed drivers: 

201  https://transport.ec.europa.eu/news/road-safety-call-expressions-interest-workshops-driving-licences-directive-2022-02-08_en  
202  Only one driving school established in Ireland has been invited, the selection has been based on the completeness of the information 

provided, in particular regarding the subjects of interest expressed by the stakeholders 

68 

 
 
                                                 
40% (3,038 out of 7,532 respondents) considered the rules adequate/very adequate compared to 33% 
(2,491 out of 7,532 respondents) considering the opposite.  

The  free  movement  of  persons  is  constrained  by  unnecessary  procedures  related  to  driving 
licences 

In the open public consultation, when asked to evaluate the current EU rules to facilitate the free 
movement of people in the European Union, most respondents believed them to be adequate/very 
adequate.  76%  of  the  respondents  (5,745  out  of  7,532  respondents)  believed  the  rules  on  the 
recognition  of  driving  licences  when  travelling  in  another  Member  State  to  be  adequate/very 
adequate. Similarly, the rules for renewal, replace or exchange of a driving licence are perceived as 
adequate/very adequate by about 54% of respondents (3,132 out of 7,532 respondents). However, 
respondents were unsure on how to evaluate the rules on obtaining a driving licence as a resident in 
another Member State. Only 42.3% of respondents (3,186 out of 7,532 respondents) believed them 
to be adequate/very adequate.  

4. FEEDBACK RECEIVED ON PROBLEM DRIVERS 

Presence of drivers with insufficient skills, knowledge, experience and/or risk awareness on EU 
roads 

In the OPC, a clear majority of respondents rated improving drivers’ skills and knowledge as either 
extremely/very important (about 44%, 3,358 out of 7,532) or important (37%, 2,829 out of 7,532). 
Stakeholders  demonstrated  an  even  greater  support  for  improving  drivers’  experience  and  risk 
awareness: about 54% of respondents (4,137 out of 7,532) rated it as extremely/very important. In 
the targeted  survey, 59% of respondents  from  national  authorities  agreed that insufficient driving 
experience and/or risk awareness in particular of novice drivers is a very/important problem vis a vis 
road  safety  (19).  In  the  targeted  survey,  74%  of  the  non-governmental  organisations  agreed  that 
insufficient driving experience and risk awareness of novice drivers is an important problem for road 
safety (22/30).  

During the targeted interviews, DE, BE, NL, BG, FI, SE and FR expressed the need for updating test 
requirements  and  standards  (integrating  new  forms  of  technology,  such  as  autonomous  driving, 
ADAS, eco-driving, the ability to use navigation, knowledge related to alternatively fuelled vehicles 
and the updates brought by the CPC for professional drivers).  

The aspect of insufficient skills and knowledge concerning new safety technologies (e.g., ADAS) 
was  assessed  as  moderately/important  vis  a  vis  road  safety  by  about  50%  of  respondents  in  the 
targeted survey with national authorities (16), whereas only 6% of respondents (2) did not consider 
it as a problem. 53% of the respondents from non-governmental organisations assessed insufficient 
skills and knowledge regarding new safety technologies as an important or very important problem 
(16/30).  

Concerning minimum standards for trainers, 41% (13) and 34% (11) of respondents in the targeted 
survey from national authorities assessed the insufficient skills and knowledge of driver trainers to 
adequately prepare drivers and ensure they have the skills and knowledge to drive as very/important 
and  moderately/slightly  important,  respectively.  Among  respondents  from  non-governmental 
organisations,  50%  deemed  insufficient  skills  and  knowledge  of  driver  instructors  to  adequately 
prepare drivers as an important aspect of road safety (15/30).  

Concerning  examiners,  about  41%  of  respondents  from  national  authorities  (13)  stated  that 
insufficient skills and knowledge of driving examiners to adequately test applicants a very/important 

69 

 
problem.  47%  of  respondents  from  non-governmental  organisations  found  insufficient  skills  and 
knowledge of driving examiners to be an important issue (14/30).  

Only FR expressed a need for common standards on the probation period for novice drivers, while, 
79% of respondents from national authorities (22) confirmed to impose restrictions in the form of 
probation periods. 

In the targeted survey, 56% of respondents (18) from national authorities assessed the insufficient 
skills and knowledge of all drivers of new mobility solutions with a maximum speed between 25 and 
45 km/h as a slightly/moderately important problem. 50% of the respondents from non-governmental 
organisations assessed insufficient skills or knowledge of drivers of new mobility solutions important 
or very important (15/30). During interviews, Member States did not believe that an extension of the 
scope of the  Directive to  new mobility solutions  (e.g. e-scooters),  or the  creation of specific new 
vehicle categories for such mobility solutions, could have an impact on road safety. 

When it comes to the minimum age for driving, FI considers it should be lowered for B category to 
enable  people  in  sparsely  populated  areas  of  the  country  to  move  around.  In  the  OPC,  more 
respondents (43%) had the same position. Other consulted stakeholders, either during interviews or 
workshops, including DE, SE, ETF, ETSC and DKU indicated that a general lowering of the age for 
driving with a B licence would have negative effects, although generally supporting accompanied 
driving at the age of 16.  

Non-governmental organisations were divided on the potential impacts of reducing the age limit for 
B licence to 16 years, while on the issue of requiring accompanied driving onto road safety: 36% of 
the non-governmental authority respondents considered it would have a positive impact (8), 27% of 
the non-governmental authority respondents considered it would have a negative impact (6) and 36% 
of the non-governmental authority respondents did not indicate their opinion (8).  

Concerning professional driving and its impact on road safety, some interviewed stakeholders (NL, 
BE, SI, ETSC, BG, and  SE) believed that lowering the age would have negative impacts on road 
safety. On the other hand, DE supported the lowering of the minimum age for category C licences to 
18, whereas  FI  supported lowering the  age for professional  driving to  18  years for both  C and D 
licences. FR called instead for more training for professional drivers, especially on risk perception. 
The lowering of the minimum age for a D licence to 18 years is considered to have no impact (26%), 
somewhat positive (25%) or somewhat negative impact (15%) on road safety by respondents to the 
OPC.  In  the  OPC,  respondents  have  identified  a  need  for  simplifying  the  access  to  licences  for 
commercial vehicles (67%). 

Presence of drivers with dangerous behaviour on EU roads 

The absence of a clear EU framework for the mutual recognition of driving disqualifications poses 
challenges when it comes to preventing abuse by drivers, and it impacts road safety. This finding was 
corroborated by Member States during the targeted interviews. Reducing both dangerous behaviours 
by drivers  and the number of unlicensed drivers  seem  to  be  relevant  factors for stakeholders that 
responded to the OPC. In effect, about 55% (5,063 out of 7,532) and 69% (5,201 out of 7,532) of 
them, respectively, rated them as extremely/very important.  

In the targeted survey, a large majority of representatives from national authorities identified the fact 
that residents and non-residents do not face the same consequences regarding driving disqualification 
in  the  EU  as  a  generally  important  problem  (16/21).  In  the  targeted  survey,  respondents  from 
non-governmental  organisations  agreed  that  residents  and  non-residents  not  facing  the  same 
consequences regarding driving disqualification is an important problem in relation to road safety 

70 

 
(64%).  Similarly,  they  agreed  that  residents  and  non-residents  not  facing  the  same  consequences 
regarding penalty/demerit points is an important problem in relation to road safety (64%).  

National  authorities  estimated  that,  on  average,  the  number  of  offences  resulting  in  driving 
disqualifications committed per year is in the range of 25,000-above 50,000. The number of driving 
disqualifications  for  domestically  registered  drivers  (e.g.,  driving  licence  is  issued  in  the  same 
Member State that imposes the disqualification) was estimated in the range 0-5,000. The number of 
driving disqualifications for drivers registered in another EU Member State (e.g., driving licence is 
not issued in the Member State that imposes the disqualification) was estimated in the range 0-5,000. 
The number of driving disqualifications for drivers registered in third countries EU Member State 
(e.g., driving licence is not issued in Europe) was estimated in the range 0-5,000. More respondents 
estimated the number of offences resulting in penalty/demerit points committed per year in the range 
0-1,000. Slightly more  respondents  estimated the number of offences resulting in  penalty/demerit 
points for domestically registered drivers (e.g., driving licence is issued in the same Member State 
that imposes the penalty/demerit point) in the range 0-1,000. The number of offences resulting in 
penalty/demerit points for drivers registered in another EU Member State (e.g., driving licence is not 
issued in the Member State that imposes the disqualification) was estimated in the range 0-5,000. 
The number of offences resulting in penalty/demerit points for drivers registered in third countries 
(e.g., driving licence is not issued in Europe) was estimated in the range 0-1,000. 

Sixteen  of  21  national  authorities  and  13  non-governmental  organisations  that  responded  to  the 
targeted  survey  assessed  the  fact  that  fraudulent  drivers  (with  illegally  obtained  driving  licences) 
continue to drive on EU roads as an important problem for road safety.203 

Thirteen of 21 respondents to the targeted survey  for national authorities and 15 NGOs identified 
current  approaches  to  the  rehabilitation  of  disqualified  drivers  as  inadequate  to  keep  dangerous 
drivers off EU roads. 

Presence of drivers that are not fit to drive on EU roads 

According to OPC results, respondents consider improving the Directive to ensure drivers’ physical 
and mental fitness as either extremely/very important (about 55%, 4,190 out of 7,532) or important 
(about 30%, 2,274 out of 7,532). In the targeted survey, more respondents from national authorities, 
(8)  confirmed  the  existence  of  the  problem  of  inadequate  medical  screening  of  all  drivers  as 
moderately/important, compared to 4 respondents that did not identify it as a problem for road safety. 
Ten respondents from non-governmental organisations considered medical screening of all drivers to 
constitute an important (8) or very important (2) problem for road safety, while 7 respondents find it 
to be a slightly important (3) or not a problem at all for road safety (4). Overall, non-governmental 
organisations argued that the focus on medical requirements in Annex III is too narrow and that there 
is a lack of clinical guidelines and scientifically validated criteria. Indeed age-related requirements 
are  considered  to  result  in  suboptimal  results,  while  the  focus  should  be  placed  on  functional 
requirements  to  drive.  The  role  of  visual  function  to  be  fit  to  drive  was  emphasised  by  various 
stakeholders.  

In the targeted survey, we asked representatives from national authorities to indicate estimates on the 
average number of traffic fatalities from 2019 where drivers’ medical condition was a contributing 
factor. 16 out of 22 respondents estimated a range of 0-25 traffic collisions in 2019 attributed to driver 

203  According to six out of seven respondents, the number of forged EU licences per year per Member State could go up to 500, and 
the number of traffic collisions that can be attributed to driving licence fraud (e.g., where the offender held a fraudulent licence) 
per year is also estimated in the range 0-500. 

71 

 
                                                 
medical condition/fitness to drive, regardless of drivers’ age; 15 out of 22 respondents estimated a 
range of 0-10 traffic collisions in 2019 attributed to driver medical condition/fitness to drive of drivers 
below 50 years; 17 out of 22 respondents estimated a range of 0-25 traffic collisions attributed to 
driver medical condition/fitness to drive of drivers above 50 years. The following table details the 
distribution  of  estimates  on  the  number  of  traffic  fatalities  from  2019  where  the  drivers’  medical 
condition was a contributing factor per respondent country to the second targeted survey. 

Table 11. No. of traffic collisions attributed to driver medical condition/ fitness to drive (second survey results) 

Member State 

LT 

DE 

PT 

FI 

Overall 

Below 
50 
years 

Above 
50 
years 

13 

3 

10 

388 

223 

165 

284 

102 

248 

352 

- 

When  asked  to  indicate  the  most  common  illnesses  that  are  the  cause  of  traffic  collision  in  their 
respective countries, 10 public authorities responded with the following ranking: 

1.  Substance dependency (5,4 out of 8) 
2.  Cardiovascular disease / Epilepsy (4,6 out of 8) 
3.  Epilepsy 
4.  Reduced mobility / diabetes mellitus (4,3 out of 8) 
5.  Mental disorders (4,1 out of 8) 
6.  Cerebrovascular diseases (3,5 out of 8). 

Applicants  face  difficulties  to  obtain  a  driving  licence  due  to  inadequate  or  unnecessary 
procedures 

In the OPC 4,462 out of 7,532 respondents (59%) considered it extremely/very important to remove 
unjustified obstacles to obtaining driving licences in the Directive.  

During interviews, most interviewed Member states found that the definition of normal residence is 
problematic. The importance of the problem  was confirmed by  12 out  of 20  representatives from 
national  authorities  responding  to  the  targeted  survey.  In  the  targeted  survey,  most  of  the 
non-governmental respondents could not assess the importance of the issue of applicants having their 
application rejected due to difficulties proving their normal residence (12/22). 

In the case of first-time issuance of driving licences, applicants can find barriers when it comes to 
e.g.,  moving  to  another  Member  State  after  having  done  a  theoretical  driving  test  or  a  medical 
examination in their Member State of origin. During the interviews, the lack of mutual recognition 
of theoretical driving tests has not been acknowledged to have a relevant impact on the freedom of 
movement of persons in the European Union (FI, SE, and FR). In the targeted survey, only 3 out of 
20  respondents  from  Member  State  did  not  consider  it  a  problem,  whereas  12  other  respondents 
assessed that it is an important problem, to different degrees. Also, in the case of medical tests taken 
abroad, all respondents from national administrations stated in the targeted survey that their countries 

72 

 
 
 
do not recognise the validity of medical checks administered by authorities in other Member States 
(AT, BG, HR, DK, FI, LU, PT, SK, SI, and SE).  

Another issue that applicants experience is the fact that, when moving to another Member State, they 
cannot pass the tests to obtain their licence in the Member State of residence if they do not speak the 
language  or  English.  This  was  generally  perceived  as  an  important  problem  by  a  majority  of 
respondents to the targeted survey from national authorities, although to different degrees (14/20). 
Representatives  of  national  authorities  were  less  convinced  of  the  importance  of  the  following 
problem (7/20): applicants for graduated access for motorcycles have to pass through cumbersome 
and costly procedures to obtain their licence.  Eighteen Member States indicated that they already 
offer tests, either theoretical or practical or both, in English and/or allow the use of an interpreter. In 
addition, some countries offer tests in several other languages (e.g., Norway offers theory tests for 
category B in Sami, Arabic, Sorani and Turkish; Sweden offers theory tests in 14 languages; Slovakia 
offers tests in the languages of minority groups living in the country). Furthermore, in the targeted 
survey country representatives have indicated an average number of 2290 for tests taken by driving 
licence applicants with support from an interpreter for 2019 (based on targeted survey estimates from 
Bulgaria, Croatia, Finland, Luxembourg, Malta, Norway, Portugal, Slovenia, and Sweden). 

Holders of licences face difficulties to have their driving rights maintained or recognised due 
to inadequate or unnecessary procedures 

Respondents to the OPC stated that removing obstacles to renewing, replacing or exchanging driving 
licences issued by EU/EEA Member States is extremely/very important (about 58%, 4,428 out of 
7,532). Also, the removing of obstacles to renewing, replacing or exchanging driving licences issued 
by  non-EU  countries  was  rated  as  either  extremely/very  important  (48%,  3,612  out  of  7,532)  or 
important (24%, 1,818 out of 7,532).  

According to interviewed Member States, the ease of exchanging a driving licence issued by a third 
country  varies  substantially  across  the  EU:  for  instance,  BG  uses  the  same  requirements  for  the 
exchange of driving licences that third countries apply to them, FI exchanges all third country licences 
without an exam for category 1, SE does not exchange any third country driving licences (with a few 
exceptions, e.g., Japan, the UK), and FR exchanges licences from 103 countries. It results in very 
inhomogeneous  treatment  of  third  country  migrants  depending  on  their  EU  Member  State  of 
residence.  

More than half of respondents from national authorities in the targeted survey, considered the issue 
of  third  countries’  driving  licence  holders  encountering  difficulties  in  exchanging  their  licence  in 
Member States as an important problem, to different degrees (11/20). The indistinct establishment of 
the normal residence across Member States can constitute an obstacle to the exchange and renewal 
of a driving licence. In the targeted survey, representatives from Member States could not estimate 
the  number  of  cases  of  requests  for  exchange  or  renewal  of  licences  that  were  rejected  due  to 
non-compliance  with  the  requirements  on  normal  residence  due  to  unavailable  statistics.  In  the 
targeted survey, almost half of the non-governmental authorities could not assess the importance of 
the issue of exchanging third countries licences with European licences (10/22). The rest were divided 
with 32% of the respondents finding it to be an important problem (7) and 14% finding it to not be 
such an important issue (3). When it comes to the issue of recognition of exchanged driving licence 
after moving to another Member states, over half of the non-governmental authorities could not assess 
its importance as an issue and 27% of the participating non-governmental authorities considered it to 
be an important problem (6). 

73 

 
Most  of  the  respondents  to  the  targeted  survey  from  national  authorities  considered  the  fact  that 
drivers  cannot  make  use  of  their  digital  driving  licence  when  driving  on  the  territory  of  another 
Member State a problem (10/18). Only one respondent did not consider it a problem. Interviewed 
Member States (Bulgaria, Belgium, Netherland, France, Slovenia, Finland, Germany, and Sweden) 
generally  agreed  that  the  lack  of  introduction  of  the  EU  mobile  driving  licence  impacts  free 
movement of those EU drivers that currently hold a digital driving licence. In the targeted survey, 
half of the non-governmental respondents considered the fact that drivers cannot make use of their 
digital driving licence when driving on the territory of another Member State as an important (7/22) 
or very important (4/22) problem when it comes to imposing unnecessary administrative burden and 
costs on drivers.  

When  renewing  their  driving  licence  in  another  Member  State,  drivers  have  the  administrative 
validity period of their licence affected (reduced), as a different administrative validity period will be 
applied than the one in their Member State of origin. The importance of this issue in accordance with 
representatives  from  Member  States  responding  to  the  targeted  survey  is  unclear:  7  out  of  20 
respondents stated that it is an important problem to different degrees, and 7 others that it is not a 
problem. Also, drivers have to pass additional medical checks if they move to another Member State 
imposing  stricter  requirements  on  medical  checks  (in  case  of  renewal,  exchange  of  replacement). 
This was considered as an important problem by more respondents (9/20), than the ones that did not 
consider it as such (5/20). 

In the targeted survey, representatives of national authorities were asked to indicate whether their 
countries impose stricter rules for professional drivers, drivers above a certain age and novice drivers 
when it comes to validity periods and medical checks. For the first category, 65% of respondents 
stated  that  their  countries  increase  frequency  of  medical  checks,  45%  that  administrative  validity 
periods  are  reduced,  and  35%  responded  that  other  requirements  are  applied,  such  as  refresher 
courses. 55% of respondents also indicated that medical checks’ frequency is increased in the case 
of  drivers  above  a  certain  age.  For  this  category  of  drivers,  35%  of  respondents  stated  that  their 
countries reduce administrative validity periods and the other 35% applies other requirements. For 
novice drivers, 80% of respondents  indicated to  apply other requirements,  e.g., refresher  courses, 
probation  periods,  less  penalty  points  etc.,  whereas  20%  responded  that  administrative  validity 
periods are reduced and 5% that the frequency of medical checks is increased. In the targeted survey, 
37% of non-governmental authority respondents  considered that drivers having the administrative 
validity  period  of  their  licence  affected  if  they  move  and  want  to  renew  their  licence  in  another 
Member states as an important issue (8). 

Most respondents to the OPC (about 66%) stated that improving the mutual recognition of driving 
licences is extremely/very important.  

5. FEEDBACK RECEIVED ON POSSIBLE SOLUTIONS  

Update  of  standards  on  skills  and  knowledge  (through  theoretical  tests  and  where  needed 
practical tests), to cover driver hazard perception, risk factors related to micro mobility means, 
advanced driving assistance systems, increasingly  automated vehicles, safety of alternatively 
fuelled vehicles 

In the OPC, 5,787 out of 7,532 respondents stated that improving the provisions of the Directive on 
the standards on drivers’ skills and knowledge is extremely/very important to meet EU road safety 
targets and to remove the obstacles to free movement. 

74 

 
 
Hazard perception 

Most interviewed stakeholders (FI, FR, SE, FIA, ETSC, ACEM and DKU) supported their inclusion 
in theoretical tests, also through digital means. In the targeted survey, most respondents from Member 
States assessed the impact on road safety of requiring a theoretical hazard perception test as positive 
(16/24). Most respondents, however, could not assess the impact of such measure on free movement. 
Costs for national authorities are expected to somewhat increase (15/24). Costs for businesses are 
expected  either  to  be  possibly  increased  by  the  measure  (7  non-governmental  stakeholders), 
decreased  (4  responses)  or  experience  no  impact  (8  responses).  Moreover,  16  non-governmental 
organisations found theoretical hazard perception tests to have a large positive impact on road safety 
and 6 found that it has a small positive impact.   

Micro mobility 

Some  interviewed  stakeholders  called  for  a  common  definition  of  micro  mobility  first  and  more 
cohesion between the Directive and the type approval regulation (DE and SE). The DKU, FIA and 
ETSC would support including users of micro mobility under the group ‘other vulnerable road users’ 
in the Directive. In the targeted survey, representatives from Member States assessed the impact of 
including users of micro mobility under the group vulnerable road users as generally positive on road 
safety (14/24).  

Most respondents could either not assess the impact of such measure on free movement (11/24) or 
assessed that the measure does not yield any impact (6/24). Concerning the costs for businesses, more 
respondents could either not assess them (9/24) or expected such costs to somewhat increase (6/24). 
Costs for drivers are expected to somewhat increase (10/24), although about 7 respondents out of 24 
could not assess them. Costs for national authorities are generally expected to increase (12/24). 

ADAS 

Some  interviewed  stakeholders  (FI,  ETSC,  and  FIA)  strongly  supported  the  inclusion  of  ADAS 
notions in theoretical tests. In the targeted survey, 63% of non-governmental organisations found the 
inclusion of questions on advanced driver-assistance systems in theoretical exams to have a positive 
impact  on  road  safety  (19.  43%  of  non-governmental  organisations’  respondents  considered  that 
including  questions  on  advanced  driver-assistance-systems  in  theoretical  exams  would  have  no 
impact on theoretical exams (13). 27% considered that it would have a positive impact (8) and 30% 
had no opinion (9). Non-governmental organisations are quite divided on whether including questions 
on advanced driver-assistance systems in theoretical exams would impact business costs. While 27% 
believe it would have no impact, 17% of the respondents thinks that it would decrease the costs and 
23% think that it would increase the costs.  

Safety of new technologies 

With regards to updating training and testing of new technologies, a majority of respondents to the 
OPC (about 57%, 4,272 out of 7,532) believed that it should be done on a voluntary basis.  

FIA, ETSC, DKU and SE supported during interviews the inclusion of questions related to electric 
vehicles in theoretical exams. Similarly, 29% of non-governmental authority respondents consider 
that including road-safety related questions for electric vehicles in theoretical exams would have no 
impact for national authorities (8/28) and 29% believe it would somewhat (7/28) or substantively 
(1/28) increase the cost for national authorities.  

75 

 
 
Climate and environment 

The adjustment of training to the needs of climate and the environment seems to be a relevant factor 
for  stakeholders.  About  53%  of  respondents  to  the  OPC  believed  that  the  establishment  of  more 
stringent  standards  on  eco-driving  skills  to  be  met  at  the  driving  test  can  have  a  positive 
environmental  impact.  This  was  reinforced  during  the  workshops,  where  it  was  highlighted  that 
sustainable mobility, multimodality should be promoted during training programmes (Italy, ECF). 
Also,  a  majority  of  respondents  (53%,  5,073  out  of  7,532)  stated  that  EU  rules  on  driving  skills 
affecting the emission and energy consumption of vehicles is relevant for the EU objective of climate 
neutrality by 2050.  

Driving rights will be associated to vehicles with the automatic gear transmission used for the 
driving  test.  The  restriction  on  the  use  of  manual  vehicles  will  be  removed  after  a  certified 
training with manual gear transmission (before or after the driving test) or a short practical 
test 

Many  interviewed  stakeholders  (DE,  FI,  SI,  BE,  NL,  SE,  FIA,  DKU  and  to  some  extent  ETSC) 
supported the proposal to remove code 78 for drivers who conducted practical tests in an automatic 
geared vehicle, upon completing a minimum of hours training taken in a manual geared vehicle. In 
the targeted survey, representatives from national authorities were divided when assessing the impact 
on road safety of removing code 78 upon minimum training. In the targeted survey of representatives 
from national authorities, 6 out of 24 respondents assessed the impact as positive, 6 as negative and 
5 did not see this measure producing any impact on road safety. Non-governmental stakeholders were 
divided on the questions of removing code 78 upon minimum training: while 10 of 30 respondents 
find that it will have a positive impact, the same number considered that this measure would have no 
or a small negative impact on road safety.  

Respondents to the targeted survey for MS either could not assess the impact on free movement of 
such  measure  (10/23)  or  expected  a  rather  positive  impact  (7/23).  Moreover,  impact  on  costs  for 
drivers and businesses could not clearly be specified. 

In the OPC, stakeholders were asked to assess the relevance to the objective of climate neutrality by 
2050  of  the  existing  restrictions  when  the  driving  test  is  passed  on  a  vehicle  with  automatic 
transmission. 51% of respondents do not perceive the current restrictions to be relevant to achieve 
climate neutrality.  

The  rights  associated  to  vehicle  categories  will  be  updated  and  aligned  -  driving  licences  of 
categories  A1,  A2  and  A  will  allow  driving with  a  trailer  (mass  to  be  determined)  -  driving 
licence of category B will allow driving alternatively fuelled vehicles of a mass not exceeding 
4,25t (equivalence which is optional under article 6(4)(c) will become mandatory including for 
transport of persons) 

In the OPC, 6,223 out of 7,532 respondents (almost 83%) considered that improving the definition 
of vehicle categories is extremely/very important. A number of policy measures on vehicle categories 
has been presented during interviews, including (i) increasing the maximum weight of B-category 
vehicles, from 3.5t to 4.25t, potentially with restrictions and/or limited scope, (ii) allowing users with 
an A-licence to drive with a trailer, (iii) removing or simplifying the graduated access scheme for 
A-licences.  

DE, BG, FR, FI, FIA supported the first measure (i), whereas BE, NL, SE and the DKU supported 
the measure only for campervans, electric vehicles, and vehicles with social function. In contrast, the 
ETSC was against such measure as increasing the weight would increase the risk and more training 

76 

 
would be needed. In the OPC, a large majority of respondents (87%) considered it very important 
that in the revision of the Directive the maximum mass of vehicles for category B is increased to 
4,25t and subject to a specific training. Such findings were confirmed during the workshops, with a 
wide agreement on increasing the maximum weight. During the Inception Impact Assessment, 2,057 
out of 2,213 respondents  recommended  to  increase the maximum  mass to 4,25t  or more. A large 
majority of respondents to the OPC (76%, 5,741 out of 7,532) further considered such measure to 
have  a fully positive impact  on  road safety. More respondents  to  the  targeted survey for national 
authorities believed that increasing the maximum weight of B-category from 3.5 to 4.25t could have 
a  negative  impact  on  road  safety  (9/18),  but  a  positive  impact  on  free  movement  (9/18).  Views 
regarding  the  costs  of  these  measures  vary,  but  costs  for  businesses  and  citizens  were  thought  to 
decrease by 7-8 national authorities, while costs for administrations may increase according to 6 of 
them. 

On the second point (ii), DE, FI, BG, BE, NL and SI would support allowing users with an A-licence 
to drive with a trailer, while FR and SE instead did not see the need for this measure. In the targeted 
survey, representatives from national authorities were divided between no impact of the measure on 
road safety (4/18) or a small negative impact (4/18). A positive impact on free movement was instead 
foreseen by more respondents (7/18), whereas no impact was expected on costs for business (7/18) 
and costs for national authorities (7/18). Costs for drivers were expected to decrease as a consequence 
of the measure (6/18).  

Concerning  the  removal  or  simplification  of  graduated  access  to  A  licence  (iii),  DE,  FR,  SE  and 
ACEM support the graduated access and would not wish the system being changed. On the other 
hand, NL, BE and SI indicated that there has been no hard data to confirm the graduate access scheme 
has  a  positive  effect  on  road  safety.  In  the  targeted  survey,  non-governmental  organisations 
emphasised that staged access for A-licences should be removed as it has no impact on the costs for 
businesses,  drivers  and  small  impacts  on  free  movement  while  increasing  the  cost  for  national 
authorities.  More  representatives  from  national  authorities  indicated  in  the  targeted  survey  that 
removing the graduated access scheme for A-licences would have a negative impact on road safety 
(10/18). No impact on free movement and costs for business was foreseen (6/18) (5/18). Costs for 
drivers were expected to decrease by more respondents (9/18). In the targeted survey, most of the 
non-governmental  organisations  found  that  removing  the  graduated  access  scheme  for  A-licences 
would  have  negative  impacts  for  road  safety  (13/22).  Regarding  the  impacts  on  free  movement, 
non-governmental organisations were divided: 32% believed it would have positive impacts (7), 9% 
believed it would have no impact (2) and 23% believed it would have negative impacts onto free 
movement (5).  

The use of RESPER for the purpose of enforcement will be improved to make it more effective 
during  roadside  checks.  RESPER  will  allow  information  exchanges  regarding  driving 
disqualifications. 

Among MS authorities that responded to the targeted survey, the following already use RESPER for 
enforcement  purposes:  HR,  FI,  SE,  whereas  almost  all  countries  that  answered  the  survey  use 
RESPER  for  administrative  purposes  (AT,  BG,  HR,  DK,  FI,  LU,  NO,  RO,  SK,  SI,  and  SE). 
According to survey respondents from national authorities, RESPER is still insufficiently used both 
for administrative and enforcement purposes. 

The  standards  on  physical  and  mental  fitness  (Annex  III)  will  be  updated:  vision,  diabetes, 
dependences and disorders. 

77 

 
In the OPC, stakeholders strongly expressed the need for improving the provisions of the Directive 
on standards on drivers’ physical and mental fitness. About 76% of respondents (5,718 out of 7,532), 
in fact, stated that improving such standards is extremely/very important. During interviews, Member 
States (DE, FI, SE, BG) and other stakeholders (DKU, ACEM, FIA, ETSC) have generally agreed 
with the need to update minimum standards of physical and mental fitness for driving (Annex III) in 
order to reflect current scientific evidence. This applies to changes in the following domains: visual 
field defects, diabetes and blood sugar in interstitial fluid measurements, and narcolepsy. During the 
workshops, NL, FR and DK supported updating Annex III to make more room for vision provisions 
and requirements and update provisions on diabetes.  

Rules  on  the  use  of  technologies  to  mitigate  medical  unfitness  (e.g.,  alcohol  lock)  will  be 
developed 

Introducing rules on the use of technologies to increase inclusiveness and compensate for reduced 
medical  fitness,  as  in  the  example  of  alcohol  interlocks  has  been  supported  by  interviewed 
stakeholders (FI, FIA, BG, SE, DKU). In the survey, more respondents (9/21) assumed a positive 
impact on road safety resulting from this measure. A majority of respondents could not assess its 
impact on free movement (12/21), costs for business (12/21), costs for drivers (14/21) and costs for 
national  authorities  (11/21).  In  the  survey,  thirteen  (57%)  of  the  participating  non-governmental 
organisations  believed  that  allowing  the  use  of  technology  to  increase  inclusiveness  will  have  a 
positive impact on road safety.  

Clarification regarding the establishment of normal residence will be established, in particular 
to cover cases with no and multiple normal residences (first 6 months in a new country, cases 
where two - or more - MS consider they can be issuing authority, special cases) 

The establishment of normal residence can have an impact on the issuance, renewal, replacement and 
exchange  of  driving  licences.  In  the  OPC,  more  than  60%  of  respondents  (5,114  out  of  7,532), 
considered necessary to improve the provisions of the Directive concerning issuing, renewing and 
replacing  of  driving  licences  and  their  exchange  when  relocating  elsewhere  in  the  EU  as 
extremely/very important.  

Adopting interpretative guidelines to assess normal residence was assessed positively by respondents 
in  the  survey  for  national  authorities,  especially  for  its  impact  on  road  safety  (12/19)  and  free 
movement  (11/19).  When  assessing  the  impacts  of  such  measure  on  costs  for  business,  more 
respondents  were  divided  between  decreasing  costs  (5/19)  and  no  impact  at  all  (5/19).  More 
respondents  assessed  that  the  measure  would  contribute  to  lower  costs  for  drivers  (6/19)  and  for 
national authorities (9/19).  

In the survey, half of the non-governmental organisations could not assess the impacts of adopting 
interpretative guidelines to judge normal residence onto road safety (11). The rest mostly believed it 
would have no impact  on road safety (6).  During the interviews,  SE  welcomed exemptions  to  be 
made for the establishment of normal residence for citizens that work for embassies, international 
organisations or NGOs and that live in third countries for long periods.  

Mobile  driving  licences  will  be  mutually  recognised  based  on  the  ISO18013-5  standard  and 
general principles (involving eIDAS) 

The OPC shows that  5,078 out  of  7,532  respondents  (67%) strongly support the extension of the 
Directive to introduce mobile driving licences. Most interviewed Member States (DE, BG, BE, NL, 
SI,  and  SE)  as  well  as  other  stakeholders  (ETSC,  ACEM,  and  DKU)  strongly  supported  the 
establishment of the mutual recognition of mobile driving licences. Interviewed Member States also 

78 

 
called  for  interoperability  of  mobile  driving  licences,  based  on  ISO  standards.  About  79%  of 
respondents to the OPC (5,932 out of 7,532) fully/somewhat agreed that privacy and cyber-security 
are important factors in the design and operation of mobile driving licences. During the workshop, 
FR, DG MOVE, and DG CNECT supported the harmonisation of mobile driving licences.  

Requiring the mutual recognition of mobile driving licences would have positive impacts on road 
safety and free movement, according to most respondents to the survey for national authorities (11/18 
and14/18 respectively).  

Furthermore,  about  74%  of  respondents  to  the  OPC  (5,550  out  of  7,532)  agreed  that  digital 
administration of driving licences can make it easier for people to change their place of residence to 
another Member State. 

It will be possible to have a QR code on the physical licence in the areas reserved for microchip 

During targeted interviews, requiring a digitally signed barcode on the physical licence instead of a 
microchip, was strongly supported by FIA, ACEM and the ETSC. DE, SE and FI did not oppose the 
measure in principle, however expressed concerns.  Non-governmental organisations in the survey 
could not assess the impact of requiring a digitally signed barcode on the physical licence instead of 
a microchip on road safety (11/22), while 28% believed it would have a small (1) or larger (5) positive 
impact on road safety. Similarly, most of the non-governmental organisations’ respondents could not 
assess the impact of such measure on free movement (10/22), or on the costs for businesses (11/22).  

Rules on administrative validity will be improved and simplified: - the administrative validity 
of  licences  for  A  and  B  categories  will  be  15  years  only  -  MS  will  be  able  to  reduce  the 
administrative validity in the case of temporary stay of third country nationals 

In the OPC, about 73% of respondents  (5,474 out of 7,532) stated that ensuring a same period of 
administrative validity for driving licences of category A and B is very/important to consider in the 
revision of the Directive. During interviews,  BG, as well as FIA, were supportive of harmonising 
driving licences’ administrative validity periods, but DE and FI, as well as the DKU, would oppose 
any proposal to change the status quo of 15 years administrative validity period. DE and SE also do 
not saw the need for allowing exemptions for temporary workers/residents from third countries in 
EU  Member  States  to  make  sure  that  the  administrative  validity  is  equal  to  the  duration  of  the 
work/residence permit.  

In the survey with national authorities, harmonising administrative validity periods for exemptions 
was considered to have a positive impact on road safety (8/19) and on free movement (9/19). Almost 
half of the non-governmental organisations could not  assess the impacts  of this measure onto  the 
costs for businesses (9/22), on the costs for drivers (10/22) and on the costs for national authorities 
(9/22).  

In the OPC, about  73% of respondents  (5,479 out  7,532)  believed that the scope of the Directive 
should be extended to cater for events of crisis and put in place procedures aimed at extending the 
administrative validity of driving licences during such unexpected events (e.g., COVID-19).  

An equivalence will be introduced to allow the holder of a licence of categories D1 and CE to 
drive vehicles under category DE. Optional equivalences will be mutually recognised between 
MS implementing them (new EU codes). 

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Most of the interviewed Member States (DE, FI, BE, BG, NL, FR and SE) expressed support for a 
measure allowing the equivalence D1+CE=D1E (i). This measure was expected to have no impact 
on road safety by most countries.  

On mutual recognition of optional equivalences, ACEM informed that this is already an option in 14 
Member States. Only DE and FR expressed strong support for this measure, on the other hand BG, 
NL, SE opposed the proposal. In the OPC, about 51% of respondents (3,825 out of 7,532) stated that 
the removal of the requirement to hold a licence of category C, C1, D or D1 to obtain a licence in 
category CE, C1E, DE or D1E can have a fully/somewhat positive impact on road safety, whereas 
22% of respondents (1,635 out of 7,532) considered this impact rather neutral. During the workshops, 
FR, SK and NL agreed with the first proposition of recognising optional rights. However, FR and SK 
disagreed with staging requirements for CD and DE licences.  

Rules on training and probation periods will be introduced, including standards on trainers 
and accompanying persons. Recommendation on lifelong training will also be formulated. 

In the OPC, about 66% of respondents agreed that it is very/important to extend the scope of the 
Directive by introducing rules on training and probation periods (including accompanied driving). 
The lack of harmonisation in  this  area was further emphasised in  the workshops (CERT, ETSC). 
Most interviewed stakeholders (FI, FIA, ETSC, ACEM, and DKU) agreed that rules on training need 
to  be  extended  to  cater  for  e.g.,  different  weather  and  traffic  conditions.  In  the  OPC,  57%  of 
respondents (4,998 out of 7,532) considered important introducing a minimum number of kilometres 
or hours of training required to pass a driving test in the revision of the Directive. According to a 
majority of survey respondents from national authorities, providing further rules on training would 
have a generally positive impact on road safety (17/22).  

Also, recommendations  on the content of drivers’ training programmes at the EU level  would be 
welcomed  by  most  interviewed  stakeholders  (DE,  FIA,  ETSC,  ACEM,  SE).  The  introduction  of 
recommendations on the content of drivers’ training programme was considered to have a positive 
impact on road safety by a majority of survey respondents from national authorities (15/22).  

The introduction of common minimum standards of a mandatory probation period was supported by 
a majority of respondents to the OPC (57%, 4,297 out of 7,532). In the targeted survey, the impact 
of establishing a probation period was assessed as generally positive for road safety by a majority of 
respondents from national authorities (15/24).  

Most of the interviewed stakeholders (FI, FIA, ETSC, ACEM, NL, SE, and DKU) would be in favour 
to  establishing  common  minimum  standards  for  driver  trainers,  such  as  guidelines,  common 
curriculum  and/or  common  tests.  In  the  OPC,  about  75%  of  respondents  (5,635  out  of  7,532) 
supported  having  common  standards  for  professional  driving  instructors  and  for  accompanying 
persons in the revision of the Directive.  

Concerning  examiners,  about  79%  of  respondents  to  the  OPC  (5,946  out  of  7,532)  considered 
improving standards for driving examiners as extremely/very important to achieve the EU road safety 
targets and remove obstacles to free movement. Interviewed stakeholders (FI, SE, FIA, ETSC, and 
DKU) supported the updating of training standards for examiners to include hazard perception and 
issues related to new technologies and professional communication (Annex IV).  

On lifelong training, respondents to the OPC were split: 32% of them (2,436 out of 7,532) considered 
introducing a principle of lifelong training as an important measure in the revision of the Directive, 
whereas  2,246  (29%)  were  neutral  and  2,134  (28%)  did  not  consider  it  important.  During  the 

80 

 
stakeholder workshop, it was emphasised by GDV that life-long training should be encouraged on a 
voluntary basis. The European Driving School association supports periodic training courses.  

Additional  training  will  be  required  for  holders  of  licences  for  category  B  to  engage  in 
international  and  cabotage  road  transport.  Compliance  to  the  standards  on  physical  and 
mental fitness for category 2 drivers will be required for the renewal of licences of category B 
for Light Good Vehicle drivers engaged in international and cabotage road transport. 

During the interviews, the proposal  to  introduce  an EU Code for driving in  Light  Good Vehicles 
(LGVs) was strongly supported by the ETSC, whereas it was opposed by the DKU, in contrast FI. 
SE did not oppose it but rather underlined the importance that it is related to professional driving and 
that the administrative burden resulting from it does not exceed the benefits. Other stakeholders (DE 
and  NL)  considered  such  a  code  to  be  more  relevant  in  the  context  of  the  CPC  Directive.  In  the 
survey, the impact of such proposal on road safety was assessed as positive by 8 respondents out of 
21 from national authorities, whereas 6 respondents did not believe it could produce any impact on 
road safety. Although 27% of the non-governmental organisations considered that the introduction 
of An EU code for driving light good vehicles would have no impact on businesses (8), it is worth 
noting that most non-governmental organisation respondents did not have an opinion (13/30).  

In the survey, despite 9 respondents out of 21 from national authorities could not assess such impact, 
8  respondents  were  convinced  of  the  positive  impact  on  road  safety  of  applying  the  group  2 
classification for professional drivers to light good vehicles.  

Categories  of  driving  licences  will  be  amended:  -  category  AM  will  be  updated  to  cover  all 
vehicles of a speed between 25 and 45 km/h, including micro-mobility means 

Although  in  the  OPC,  a  large  majority  of  respondents  (4,741  out  of  7,532)  considered  it 
very/important  to  integrate  such  smart  mobility  means  in  the  category  AM  in  the  revision  of  the 
Directive, most of the interviewed Member States, as well as ACEM, opposed both the creation of a 
new category and the inclusion under the category AM of micro-mobility vehicles (NL, BE, FR, FI 
and DE).  

In the targeted survey, 70% of the participating non-governmental organisations expected that policy 
measured on micro-mobility to have some positive impact (21): small for 40% of the respondent (12) 
and large for 30% of the respondents (9). While 28% of the non-governmental organisations believed 
that  it  would  have  positive  impacts  on  free  movement  (6);  32  %  of  the  non-governmental 
organisations  believed  it  would  have  no  impact  on  the  costs  for  businesses  (7);  41%  of  the 
non-governmental organisations considered that it would increase the costs for drivers (9) and 37% 
of the remaining respondents believed it would increase the costs for national authorities (8).  

A majority of national administrations responding to the survey indicated that their countries do not 
impose specific driving licence requirements related to users of micro mobility.  

Categories of driving licences will be amended: - a new category T-EU will be introduced for 
tractors  -  the  definition  of  category  D1  will  be  updated  by  increasing  the  number  of  bus 
passengers from 16 to 22 

During  interviews,  stakeholders  were  asked  to  express  their  support  towards  (i)  introducing  a 
category for agricultural vehicles, (ii) increasing  the maximum number of passengers under a D1 
licence.  

81 

 
On the first point (i), DE, FI and SE did not see the need for such a measure, rather DE would see it 
possible that licences for agricultural vehicles are mutually recognised. In general, mutual recognition 
of licences across the European Union seems to be strongly supported by stakeholders: in the OPC, 
almost  87%  of  respondents  stated  that  the  recognition  of  driving  licences  when  travelling  in  a 
Member State other than the state of residence is extremely/very important to meet the road safety 
targets and remove obstacles to free movement in the EU. This is complimented by about 62% of 
respondents as well who that stated that it is very/important to establish mutual recognition of national 
licences  for  agricultural  vehicles  and  forestry  vehicles  when  on  the  road  in  the  revision  of  the 
Directive.  

The second proposal (ii) was opposed by DE, FR, SE and the ETSC, while it was supported by FI 
and  BG.  The  measure  was  expected  to  have  a  negative  impact  on  road  safety  by  more  country 
representatives responding to the survey (8/18), whereas positive impacts on free movement were 
expected (8/18). In the survey, almost half of the non-governmental organisations could not assess 
the impacts of this policy measure onto road safety (10/22), onto free movement (13/22), onto the 
costs  for  businesses  (14/22),  onto  the  costs  for  drivers  (13/22)  and  onto  the  costs  for  national 
authorities  (12/22).  The  remaining  respondents  were  divided  with  19%  believing  it  would  have 
positive impacts on road safety (4), 23% believing it would have no impact on road safety (5) and 
14% believing it would have negative impacts onto road safety (3). As regards free movement, most 
of the remaining respondents considered that it would have positive impacts (4/22).  

Driving disqualifications will be mutually recognised 

A large majority of respondents to the OPC (68%, 5,146 out of 7,532) stated that it is very/important 
that  the  scope  of  the  Directive  is  expanded  to  include  rules  on  the  mutual  recognition  of  driving 
disqualification.  Most  stakeholders  supported  the  mutual  recognition  of  driving  disqualifications 
during the workshop (FEVR, ETSC, CEETAR, FR, HU and NL). However, NL raised some legal 
concerns, while DE was the only stakeholder to firmly disagree with the mutual recognition. 

Overall, many stakeholders were supportive of the mutual  recognition  of driving disqualification, 
especially when it comes to offenses related to speeding, drink/drunk driving. This was confirmed in 
the OPC, where about 6,106 (81%) and 4,966 (66%) out of 7,532 respondents, considered the mutual 
recognition of driving disqualifications resulting from driving under the influence of alcohol or of 
drugs  and  from  speeding  as  very/important  for  the  revision  of  the  Directive  respectively. 
Furthermore, 62% of respondents (4,731 out of 7,532) considered the mutual recognition of driving 
disqualification for other offenses also very/important in the revision of the Directive. In specific, 
when asked which offences should be mutually recognised in the EU, 87% of respondents to the OPC 
(6,586 out of 7,532) chose driving under the influence of alcohol and drugs and 46% (3,470 out of 
7,532) selected speeding. For speeding, respondents to the OPC tended to prefer a 30 km/h minimum 
excess  above  the  speed  limit  in  urban  areas  triggering  the  mutual  recognition  of  driving 
disqualification (47%, 3,570 out of 7,532), whereas in rural areas they were divided between 50 km/h 
(38%, 2,880 out of 7,532) and 30 km/h (22%, 1,680 out of 7,532) and on motorways between 50 
km/h (32%, 2,393 out of 7,532) and 70 km/h (27%, 2,032 out of 7,532). In the targeted interviews, 
the ETSC, as well as ACEM and the DKU expressed support for the mutual recognition of driving 
disqualification resulting from speeding, drink/drunk driving. SE, SI and BE were also supportive, 
despite acknowledging the difficulties in finding an agreement with other Member States and with 
the actual implementation.  

Rules  on  consequences  of  penalty  points  for  non-residents  will  be  established.  Rules  on 
rehabilitation in case of a change of normal residence will be established 

82 

 
During the targeted interviews, stakeholders were asked to express their views on a series of measures 
to harmonise the regime for driving disqualification throughout the EU, namely: 

Specifying minimal rehabilitation periods or activities for imposed disqualifications. 

DE expressed a negative view. SE questioned the need to harmonise rehabilitation periods. SE uses 
the probation periods for drunk driving to incentive the use of alcohol interlocks and considers that a 
harmonised  approach  for  probation  could  jeopardise  this  incentive.  The  DKU  on  the  other  side 
expressed  support  for  such  harmonisation  effort.  In  the  survey,  more  respondents  from  national 
authorities indicated that this measure would have positive impacts on road safety (13/20).  

On introducing a harmonised system for penalty points in the Directive, and applicable sanctions: 

FI,  DE  and  SE  expressed  negative  views  on  the  harmonisation  of  systems  of  penalty  points.  In 
contrast,  BG  and  the  DKU  would  support  it,  despite  foreseeing  difficulties  to  find  an  agreement 
among Member States and in terms of practical implementation.  

During the workshop, the introduction of a harmonised penalty point system at the European level 
was supported by some stakeholder (FR, ETSC). SE shared some reservation, pointing out the risk 
of  points  shopping  in  other  Member  States  if  there  is  mutual  recognition.  In  the  survey,  more 
representatives from national authorities assessed that the measure would have a positive impact on 
road  safety  (11/20).  The  impact  on  free  movement  was  non-assessable  for  more  than  half  of  the 
respondents  (11/20),  while  the  other  half  were  divided.  In  the  survey,  non-governmental 
organisations  considered  that  introducing  a  harmonised  system  for  penalty  points  would  have  a 
positive impact on road safety (14/22). Non-governmental organisations were divided on the question 
of  its  impact  on  free  movement:  32%  considered  that  it  would  have  a  positive  impact  on  free 
movement (7), 14% considered that it would have no impact (3), 18% considered that it would have 
a negative impact (4) and 36% could not assess the impact of such measure on free movement (8). 
45% of non-governmental organisation respondents could not assess the impact of such measure on 
the costs for businesses (10) and 41% of the respondents considered that such measure would have 
no impact on the costs for businesses (9). While 45% of the respondent could not assess the impact 
of such measure on the costs for drivers (10), 36% of the respondents considered that it will have no 
impact on the costs for drivers (8). Non-governmental organisations were divided on the impacts of 
this measure on national authorities costs: 37% of the respondents considered that this measure will 
increase the costs for national authorities (8), 14% of the respondents considered that it will have no 
impact on the costs for national authorities (3) and 14% of the respondents considered that it will 
decrease the costs for national authorities (3).  

On harmonising the driver disqualification sanction for speeding and drink/drug-driving: 

Most  national  authorities  are  convinced  that  harmonising  driver  disqualification  sanctions  for 
speeding and drink / drug-driving can have a positive impact on road safety. Despite more than half 
of respondents being not able to assess it (11/20), more respondents found that the measure can have 
a positive impact on free movement (5/20). 

In  the  survey,  non-governmental  organisations  indicated  that  harmonising  driver  disqualification 
sanctions for speeding and drink/drug-driving would have a positive impact on road safety (17/22). 
Non-governmental  organisations were divided on the impact  of such measure on free movement: 
37% of the respondents considered that it would have a positive impact on free movement (8), 14% 
considered that it would have no impact on free movement (3), 14% considered that it would have a 
negative impact on free movement (3) and 36% could not assess the impact of such measure (8).  

83 

 
Guidelines  on  medical  screening  and  assessment  will  be  formulated.  A  programme  will  be 
launched to support the training of general practitioners on fitness to drive. 

FIA,  ETSC,  BG  and  DKU  would  support  the  introduction  of  guidelines/recommendations  for 
standardised medical screening process for B licences. DE, on the other hand, would oppose it. In the 
survey, a majority of respondents from national  authorities (13/21) expected a positive impact on 
road safety of providing guidelines/recommendations for a standardised medical screening process 
for B licences. In the survey, 78% the non-governmental organisation respondents considered that 
providing guidelines/recommendations for a standardised medical screening process for B licences 
would have a positive impact on road safety (small positive impact: 10/23; large positive impact: 
8/23).  

The establishment of a platform for the sharing of best practices on medical check procedures adopted 
in EU Member States was supported by most interviewed stakeholders (DE, FIA, ACEM, SE, DKU, 
FI, and BG). In the survey, the measure was expected to have positive impacts on road safety by most 
representatives  from  national  authorities  (13/21).  In  the  survey,  69%  of  non-governmental 
organisation respondents found that establishing a platform for efficient sharing of best practices on 
medical checks procedures would have a positive impact on road safety (16).  

Furthermore, the establishment of a platform for sharing best practices on medical fitness procedures 
adopted in EU Member States was also considered to have a positive impact on road safety by most 
respondents from national authorities (13/21).  

Rules on physical and mental screening and assessment will be established. A programme will 
be launched to support the training of general practitioners on fitness to drive. 

In the survey, the proposal to require medical fitness to be screened at driving licence renewal for 
categories A and B was expected to produce positive impacts on road safety by more respondents 
(9/21). The impact of the measure on free movement was considered as positive by 8 respondents out 
of 21. Respondents expected an increase in costs for business and costs for drivers (6/21) (12/21), 
despite several could not assess the impact of the measure on such costs (9/21) (6/21). Also, costs for 
national authorities are expected to increase (12/21).  

In  the  survey,  70%  of  the  non-governmental  organisations’  respondents  considered  that  requiring 
medical fitness to be screened at driving licence renewal for categories A and B would have a positive 
impact  on  road  safety  (16).  Non-governmental  organisations  were  divided  on  the  impact  of  this 
measure on the free movement of drivers: while 35% of the respondents believe it will have no impact 
on the free movement of drivers (8), 21% believe it would increase free movement (5) and 9% believe 
it  would  decrease  free  movement  (2).  47%  of  non-governmental  organisations’  respondents 
considered that it would increase the costs for businesses (11), 22% of the respondents considered it 
would have no impact on the costs of businesses (5). 68% of the respondents considered that requiring 
medical  fitness  to  be  screened  at  driving  licence  renewal  for  categories  A  and  B  would  increase 
somewhat (13) or substantively (2) the costs for drivers and 41% considered that it will somewhat 
(9) increase the costs for national authorities.  

Applicants that are EU nationals shall be able to obtain their first driving licence of category B 
in  their  country  of  nationality  in  the  event  their  state  of  normal  residence  does  not  allow 
interpreters and the official language of their country of nationality is not available for test in 
the state of normal residence 

Stakeholders were asked to assess the measure to require the mutual recognition of theoretical tests. 
Such measure would allow trainees to conduct an exam in their own language, e.g., in the Member 

84 

 
State in which they were born, and conduct a practical exam in the Member State where they have 
normal  residence.  DE  and  SE  would  not  support  such  measure.  Accordingly,  traffic  rules  are  a 
national competence.  

In the OPC, respondents were not fully convinced of this proposal: 45% of them (3,395 out of 7,532) 
considered  it  very/important  to  be  considered,  whereas  about  28%  (2,135  out  of  7,532)  and  17% 
(1,265 out of 7,532) were, respectively, either neutral or opposed the proposal.  

In  the  survey,  the  possibility  of  mutual  recognition  of  theoretical  tests  was  assessed  as  having  a 
positive impact on road safety as slightly more respondents from national authorities (7/19) foresaw 
a positive impact than a negative one (6/19). Most respondents expected a positive impact on free 
movement (12/19). In the survey, almost half of the non-governmental organisations’ respondents 
considered that the mutual recognition of theoretical tests would have a positive impact on road safety 
(9), despite 36% of the respondents not being able to assess the impact of such measure (8).  

The requirement to hold a licence of category C or D to obtain a licence of category CE or DE 
is removed 

Among Member States, DE, FI and SE would support removing the staging requirement, whereas 
BG and NL opposed the proposal. In the survey for national authorities, more respondents foresaw 
negative  impacts  on  road  safety  resulting  from  this  measure  (8/18)  but  positive  impacts  on  free 
movement (7/18). The measure was also expected to decrease costs for business (8/18) and for drivers 
(9/18), whereas no impact was foreseen on costs for national authorities (5/18).  

Physical and mental assessment will be mutually recognised 

DE rejected such proposal, considering it intrusive of Member States’ competences. On the same 
line, SE opposed the measure claiming that the magnitude of the problem does not justify such a 
response. BG, as well as the DKU, would instead support the measure.  

In the survey, more representatives of national administrations answered that the mutual recognition 
of medical exams would have a positive impact on road safety (7/19), as well as on free movement 
(11/19). In the survey, 41% of the non-governmental organisations found that the mutual recognition 
of medical exams would have a positive impact on road safety (9/22), despite 32% of the respondents 
not being able to assess the impacts of such measure.  

MS  will  be  able  to  establish  an  optional  equivalence,  valid  only  on  its  territory,  allowing  a 
holder of an AM licence to drive car of which the power is physically limited to [TBC] up to 21 
years 

During the interviews, we asked stakeholder whether they would support a measure to allow Member 
States to opt for an optional equivalence for B-licence when a driver holds and AM-licence. DE, BG, 
SE, ACEM and ETSC would oppose the measure.  In the survey, most respondents  from  national 
authorities expected a negative impact on road safety resulting from allowing Member States to opt 
for an optional equivalence for B-licence when a driver has received AM-licence (10/19), whereas 
more respondents expected positive impacts on free movement (5/19).  

Half of the non-governmental organisations surveyed found that allowing Member states to opt for 
an optional equivalence for B-licence when a driver has received AM-licence would have negative 
impacts onto road safety (11/22) against 10% of the respondents arguing that it would have a positive 
impact (2). 

85 

 
Code 70 shall be removed from the licence when the driver has been holding an EU licence for 
at least 5 years and has not committed serious road traffic offenses. Former holders of a driving 
licence, obtained after passing tests in the EU shall be able to regain all their driving rights in 
exchange of a foreign driving licences when they relocate in the EU irrespective of their new 
country of residence. 

Interviewed Member States were asked to state their support to a measure that would remove code 
70  at  the  first  or  second  renewal  upon  the  condition  that  no  severe  traffic  violations  have  been 
committed. BG opposed such proposal, which was instead supported by BE, SI and SE. This measure 
was believed to have no impact on road safety by more respondents from national administrations in 
the survey (6/19). More respondents expected a positive impact of the measure on free movement 
(6/19), as well as decreasing costs for business (6/19) and costs for drivers (6/19) as a consequence 
of its implementation. No impact was foreseen on costs for national authorities (6/19).   

In the survey, almost half of the non-governmental organisations’ respondents could not assess the 
impact of removing Code 70 at the first or second renewal if no severe traffic violations were made 
onto road safety (10/22), onto free movement (9/22) and onto the costs for businesses (10/22). 32% 
believed  that  it  would  have  no  impact  on  road  safety  (7/22).  41%  believed  that  it  would  have  a 
positive impact on free movement (9/22). 32% of the respondents believe that this measure would 
decrease the costs for drivers (7/22). Yet, almost half of the respondents could not assess its impacts 
on the costs for drivers (10/22). While 41% of the respondents could not assess the impacts of this 
measure onto the costs for national authorities (9/22), 41% of the respondents believed it would have 
no impacts on the costs for national authorities (9/22).  

MS will be able to establish an optional equivalence, valid only on their territory, allowing a 
holder of a C licence to drive an empty bus 

Among interviewed Member States, DE, FI, SE, BE and NL would support allowing holders of a C 
licence  to  drive  an  empty  bus.  The  measure  was  instead  opposed  by  BG  and  FR.  In  the  survey, 
non-governmental  organisations  were  divided  on  the  impact  of this measure  on  road  safety:  32% 
believed that it would have no impact (7) and 28% of the respondents believed that it would have 
negative impacts onto road safety (6).  

Rules on the exchange of foreign driving licences will be established for Third Countries whose 
licensing system are of the same level as in the EU in term of road safety 

DE and BG expressed support for this measure. A majority of respondents to the OPC stated that it 
is  very/important  to  extend  the  scopeof  the  Directive  by  introducing  rules  on  exchanging  driving 
licences  issues  by  a  non-EU  country.  Furthermore,  about  65%  of  respondents  to  the  OPC 
fully/somewhat agreed that common rules on the exchange of driving licences issued by a non-EU 
country  are  needed  to  address  the  shortage  of  professional  drivers.  This  measure  was  perceived 
positively by more respondents from national authorities in the survey, especially for its impact on 
road safety (9/19) and on free movement (10/19).  

In the survey, half of the non-governmental organisations could not assess the impact of establishing 
a  list  of  third  countries  accessing  the  EU  framework  based  on  the  safety  of  the  foreign  licensing 
system (11/22). 32% of the non-governmental organisations found that such measure would have a 
positive impact on road safety (8). More than half of the non-governmental organisations (55%/12) 
believe that such measure will have a positive impact on free movement.  

86 

 
 
 
ANNEX 3: WHO IS AFFECTED AND HOW? 

1. PRACTICAL IMPLICATIONS OF THE INITIATIVE 

Summary of the preferred policy option implementation 

The revision of the Directive on driving licences aims at improving road safety and at facilitating the 
free movement of EU citizens.  

The benefits of the preferred policy option are expected to fall on different stakeholder groups: road 
users, national issuing authorities, law enforcement authorities, driving schools, transport operators 
and, to a lesser extent, car manufacturers.  

The  preferred  policy  option  will  increase  the  assurance  that  drivers  on  EU  roads  have  the  skills, 
knowledge,  experience  and  risk  awareness,  are  physically  and  mentally  fit  to  drive  and  that  their 
behaviour is not dangerous. Ensuring a high level of safety is important for all the road users. It will 
also  have  positive  effects  on  road  transport  operators,  driving  schools  and  law  enforcement 
authorities, since their employees and civil servants will be less exposed to safety risks.  

The driving licences will be better adapted to alternative fuel vehicles and thus to the evolution of 
the  fleet  towards  zero-emission  vehicles.  This  will  also  indirectly  benefit  car  manufacturers,  by 
facilitating  the  uptake  of  the  concerned  technologies,  and  driving  schools,  by  relaxing  potential 
constraints on vehicles to be used for training. 

The preferred policy option will also remove barriers affecting persons when obtaining or exercising 
driving rights. The most important effect will result from the introduction of mobile driving licences. 
It will allow for seamless interactions when exchanging information on driving rights. It will benefit 
all  users,  from  drivers  to  law  enforcement  authorities  and  businesses  (for  example  car  rental 
companies) and national issuing authorities. In addition, other measures will affect targeted groups 
of citizens, in particular holders of driving licences transferring to other EU countries, applicants that 
are not fluent in the language of their host country, or young persons willing to became professional 
drivers for example. 

Regarding European competitiveness, the preferred option is expected to lead to hassle cost savings for 
road transport operators since the introduction of the EU mobile driving licence is estimated to lead 
to a reduction in hassle costs for the renewal of the category C and D licences. C and D licences are 
mainly  used  by  professional  drivers  and  the  costs  savings  are  thus  expected  to  benefit  transport 
operators, mainly SMEs in the road transport sector. In addition, the preferred option will include the 
removal of the requirement to hold a licence of category C or D to obtain a licence of category CE 
or DE, which is expected to lead to  administrative costs savings for professional drivers  that will 
benefit road transport operators. The removal of this requirement would lead to a reduction in the 
number of theoretical and practical tests required to obtain a CE or DE category licence.  

Implications on road users, market actors and public authorities  

While the revision of the Directive on driving licences is an initiative benefitting all road users, the 
costs will be essentially borne by Member States’ administrations in charge of implementing it. These 
costs relate to: 

1.  Update of the procedures and standards for the issuance of driving licences. 
2.  Introduction and implementation of the mobile driving licences. 

87 

 
3.  Introduction  and  implementation  of  procedures  for  the  mutual  recognition  of  driving 

disqualifications. 

The  European  Commission  would  also  incur  some  costs  related  to  the  development  of  technical 
solutions,  notably  in  relation  to  RESPER,  and  to  the  exchange  of  information  on  medical  fitness 
between authorities. 

Citizens  will  incur  adjustment  costs  for  the  measures  on  screening  of  fitness  to  drive  for  drivers 
renewing their driving licence, independent of age (i.e. self-assessment) and vision test for applicants. 
They are also expected to incur administrative costs related to the update of standards on skills and 
knowledge for the first issuance of a driving licence. 

The initiative results in administrative cost savings for the private sector, mainly rental companies 
and transport operators, notably due to the removal of the staging requirements for category CE and 
DE licences. It also results in hassle costs savings thanks to the introduction of the mobile driving 
licence.  The  initiative  will  however  lead  to  some  additional  costs  for  general  practitioners,  for 
following (online) training on physical and mental fitness. Indirectly, as road users, some businesses 
could benefit from increased road safety. 

2. SUMMARY OF COSTS AND BENEFITS 

I. Overview of Benefits (total for all provisions) – Preferred Option (Policy option B) 

Description 

Amount 

Comments 

Direct benefits 

EUR 2.8 billion  

Member 

Enforcement  costs  savings 
States 
for 
administrations,  expressed 
as  present  value  over  2025-
2050, relative to the baseline 

Member 

Administrative costs savings 
States 
for 
administrations,  expressed 
as  present  value  over  2025-
2050, relative to the baseline 

EUR 2 billion 

Enforcement  costs  savings  for  Member 
States administrations are mainly driven by 
measures  related  to  the  mutual  recognition 
of  mobile  driving  licences,  the  possible 
introduction  of  a  QR  code  on  the  physical 
licence in the areas reserved for microchips, 
and  improvements  and  simplification  of 
rules on administrative validity. In terms of 
present 
the 
over 
enforcement  costs  savings  are  estimated  at 
EUR 2.8 billion. 

2025-2050, 

value 

savings 

for  Member 

The  introduction  of  the  EU  mobile  driving 
licence  expected  to  lead  to  administrative 
costs 
States 
administrations estimated at EUR 2 million, 
expressed as present  value over 2025-2050 
relative  to  the  baseline.  These  costs  are 
related  to  the  time  spent  to  ensure  that  the 
physical  licences  are  issued  to  the  right 
person,  and  thus  the  time  spent  to  validate 
the  identity  of  the  person  to  which  a  new 
licence  is  provided.  When  procedures  are 
digitised, the time spent on such procedures 
and the associated costs are overcome. 

Administrative costs savings 
for  citizens,  expressed  as 

EUR 2.3 million 

Administrative costs savings for citizens due 
to  the  introduction  of  rules  to  remove 

88 

 
present  value  over  2025-
2050, relative to the baseline 

Adjustment costs savings for 
citizens, 
as 
present  value  over  2025-
2050, relative to the baseline 

expressed 

Hassle  costs  savings  for 
citizens, 
as 
present  value  over  2025-
2050, relative to the baseline 

expressed 

Administrative costs savings 
for  businesses,  expressed  as 
present  value  over  2025-
2050, relative to the baseline 

EUR 4.9 billion 

EUR 1.7 billion 

EUR 0.9 billion 

Hassle  costs  savings  for 
businesses,  expressed  as 
present  value  over  2025-
2050, relative to the baseline 

EUR 0.6 billion 

the 
Improvement 
functioning  of  the  internal 
market 

in 

89 

restrictions  associated  to  automatic  gear 
transmission, estimated at EUR 2.3 million 
expressed as present  value over 2025-2050 
relative to the baseline.  

Adjustment costs savings for citizens due to 
less  frequent  medical  checks  for  drivers 
suffering of diabetes (every 10 years instead 
of  5)  and  changes  in  the  rules  for  the 
consultation of the general practitioners for 
(above  70  years  old), 
elderly  people 
estimated at EUR 4.9 billion relative to the 
baseline  (expressed  as  present  value  over 
2025-2050). 

Hassle costs savings for citizens due to the 
introduction  of  the  EU  mobile  driving 
licence, estimated at EUR 1.7 billion relative 
to  the  baseline  (expressed  as  present  value 
over 2025-2050). 

The  removal  of  the  requirement  to  hold  a 
licence of category C or D to obtain a licence 
of category CE or DE is expected to lead to 
administrative costs savings for professional 
drivers that benefit road transport operators. 
savings  are 
The  administrative  costs 
estimated at EUR 0.9 billion relative to the 
baseline, expressed as present value over the 
2025-2050 horizon. 

The  introduction  of  the  EU  mobile  driving 
licences is estimated to lead to a reduction in 
hassle costs for the renewal of the category 
C and D licences. The C and D licences are 
mainly used by professional drivers and the 
costs savings, estimated at EUR 0.6 billion 
relative to the baseline (expressed as present 
value over 2025-2050), are thus expected to 
benefit transport operators, mainly SMEs in 
the road transport sector. 

Positive  impact  on  the  functioning  of  the 
internal  market  is  expected  due  to  the 
removal  of  unneccesary  barriers 
for 
applicants  and  holders  of  driving  licences 
and facilitating free movement of people, the 
main  measure  being  an  introduction  of 
mobile  driving 
licences.  The  common 
ISO/IEC  18013-5  standard  will  ensure 
interoperability  of 
the  mobile  driving 
licences  issued  by  each  EU  Member  State 
and their recognition in the EU and abroad.  
Preferred  option  will  also 
introduce 
measures allowing faster access to licences 
of  category  CE  or  DE  for  professional 
drivers  across  the  EU  which  will  reduce 

 
 
barriers for the access  to driver profession.  
The  rules  related  to  the  concept  of  normal 
residence will also help persons transferring 
their  normal  residence  to  another  Member 
State. 

Preferred  option  is  expected  to  contribute 
positively to the freedom of movement, and 
even  if  the  number  of  persons  facing 
unnecessary  or  unjustified  procedures  is 
rather  low,  consequences  for  an  individual 
can  be  significant.  Clarification  of  the 
concept of normal residence should solve the 
problem of determining the issuing authority 
residence.  
just  after 
Simplification  of  rules  on  administrative 
validity  will  put  the  holders  of  the  EU 
driving licences on equal footing, regardless 
in which country they apply for or extent the 
licence.  Mutual  recognition  of  optional 
equivalences  will  allow  holders  of  driving 
licences  to  enjoy  rights  granted  by  an 
optional  equivalence  also  in  other  Member 
States applying the same rules.  

transfer  of 

the 

Preferred option will align DL Directive to 
the  latest  legislation  on  the  protection  of 
personal  data  through  improvement  of  the 
network  for  exchange  of  information  on 
driving  licences  RESPER  and  establishing 
the EU digital driving licence (PMc9). The 
use of the eIDAS features for the EU driving 
licence  and  EU  Wallet  for  the  storage  and 
exchange of data will ensure a high level of 
security  and  privacy  of  the  information 
handled.  Mutual  recognition  of  driving 
disqualifications  will  give  procedural 
safeguards  to  non-resident  drivers  who 
commit  road  safety  traffic  offences  and 
ensure  that  their  fundamental  rights  are 
respected. It will also have a positive impact 
on the right of  non-discrimination, given it 
will provide flexibility for the first issuance 
of  driving  licences  in  case  of  restrictions 
related  to  languages  which  will  allow 
applicants to choose where to take the tests. 

society  at 

Indirect  benefit 
large. 
to 
Significant  positive  effects  on  road  safety 
are expected, in particular due to the updated 
standards  on  skills  and  knowledge,  the 
introduction  of  rules  on 
training  and 
probation period, with a probation period for 
novice  drivers,  the  mutual  recognition  of 
driving  disqualifications  and  the  rules  on 

Improvements related to the 
free movement of people 

Contribution 
the 
fundamental rights and equal 
treatment of EU citizens 

to 

Indirect benefits 

1,153 lives saved and 11,020 injuries avoided 

Reduction  in  the  number  of 
fatalities and serious injuries 
the  baseline 
to 
relative 
(cumulative 
over 
2025-2050) 

90 

 
 
 
Reduction  in  external  costs 
of  accidents  (fatalities  and 
serious  injuries),  expressed 
as 
over 
2025-2050,  relative  to  the 
baseline 

present 

value 

EUR 7.1 billion 

Reduction in the use of 
plastic (polycarbonate), 
relative to the baseline 

130 tonnes of plastic (polycarbonate) saved 
annually 

medical  screening  and  assessment.  The 
impacts  are  estimated  at  1,153  lives  saved 
and 11,020 serious injuries avoided over the 
2025-2050, relative to the baseline.  

Indirect benefit to society at large, due to the 
lives  saved  and 
injuries  avoided.  The 
reduction in the external costs of accidents is 
estimated  at  EUR  7.1  billion,  expressed  as 
present value over the 2025-2050 horizon (in 
2021 prices) relative to the baseline. 

Indirect benefit to society at large, from the 
introduction  of  digital  driving  licence  by 
default from 2028 onwards that would result 
in  approximatively  130  tonnes  of  plastic 
(polycarbonate) saved annually. 

Administrative cost savings related to the ‘one in, one out’ approach 

Administrative costs savings 
for  citizens,  relative  to  the 
baseline (annual average)  

EUR 0.1 million per year on average 

Administrative costs savings 
for businesses, relative to the 
baseline (annual average) 

EUR 48.5 million per year on average 

Administrative costs savings for citizens are 
due  to  the  introduction  of  rules  to  remove 
restrictions  associated  to  automatic  gear 
transmission. The annual average reduction 
in  the  number  of  practical  driving  tests  is 
estimated  at  1,184  relative  to  the  baseline. 
savings  are 
The  administrative  costs 
estimated at EUR 0.1 million on average per 
year, relative to the baseline. 

for 

road 
Administrative  costs  savings 
transport operators, mainly SMEs, are due to 
the  removal  of  the  requirement  to  hold  a 
licence of category C or D to obtain a licence 
of category CE or DE. The measure would 
lead  to  a  reduction  in  the  number  of 
theoretical  and  practical  driving 
tests, 
estimated  at  510,474  on  average  per  year 
relative  to  the  baseline.  The  administrative 
costs  savings  are  estimated  at  EUR  48.5 
million per  year on average,  relative to the 
baseline. 

91 

 
 
II. Overview of costs – Preferred option (Policy option B) 

Citizens/Consumers 

Businesses 

Administrations 

One-
off 

- 

Direct adjustment 
costs, expressed 
as present value 
over 2025-2050, 
relative to the 
baseline 

Recurrent 

One-off 

Recurrent 

One-off 

Recurrent 

For citizens: EUR 
716.2 to 1159.1 
million, due to 
screening of fitness 
to drive for drivers 
renewing their 
driving licence and 
vision test for 
applicants. 

- 

For general 
practitioners: 
EUR 57.7 
million, for 
(online) training 
on physical and 
mental fitness.  

For Member 
States 
administrations: 
EUR 14.3 
million, for the 
development of 
an IT system 
for the mobile 
driving licences 
and the 
improvement of 
RESPER for 
the purpose of 
enforcement. 

For Member 
States 
administrations: 
EUR 48.9 
million, for 
maintenance of 
an IT system for 
the mobile 
driving licences 
and the 
development of 
(animated) 
videos for the 
driver hazard 
perception test. 

For the 
European 
Commission: 
EUR 0.7 to 1.1 
million, for the 
establishment of 
an information 
platform for 
authorities to 
exchange on 
physical and 
mental fitness to 
drive and the 
development of 
an (online) 
training 
programme for 
general 
practitioners. 

For Member 
States 
administrations: 
EUR 26.3 
million, for the 
investigation and 
notification of 
driving 
disqualifications. 

Direct 
enforcement 
costs, expressed 
as present value 
over 2025-2050, 
relative to the 
baseline 

- 

- 

- 

- 

- 

Costs related to the ‘one in, one out’ approach 

92 

 
 
 
 
 
- 

- 

- 

For citizens: EUR 
716.2 to 1159.1  
million, due to 
screening of fitness 
to drive for drivers 
renewing their 
driving licence and 
vision test for 
applicants. 

- 

- 

- 

- 

- 

For general 
practitioners: 
EUR 57.7 
million, for 
(online) training 
on physical and 
mental fitness. 

- 

- 

Direct adjustment 
costs, expressed 
as present value 
over 2025-2050, 
relative to the 
baseline  

Total  

Indirect 
adjustment costs 

Administrative 
costs (for 
offsetting), 
expressed as 
present value 
over 2025-2050, 
relative to the 
baseline 

3. RELEVANT SUSTAINABLE DEVELOPMENT GOALS 

III. Overview of relevant Sustainable Development Goals – Preferred Option (Policy option B) 

Relevant SDG 

Expected progress towards the Goal 

Comments 

and 

SDG  #  11  “Make  cities  and 
human  settlements  inclusive, 
and 
safe, 
resilient 
in 
sustainable” 
particular  to  target  11.2  “By 
2030, provide access to safe, 
affordable,  accessible  and 
sustainable 
transport 
systems  for  all,  improving 
road 
safety,  notably  by 
expanding  public  transport, 
with  special  attention  to  the 
needs  of  those  in  vulnerable 
situations,  women,  children, 
persons with disabilities and 
older persons” 

EU roads are expected to become safer for all road 
users by: 

- improving the skills, knowledge, experience and 
risk awareness of drivers on EU roads, 

Legislation on road use, including licensing, 
is  a  core  element  of  the  Safe  System 
Approach in road safety and a core principle 
of the  2020 UN “Stockholm  Declaration on 
road safety”204 

- ensuring mental and physical fitness of drivers 

- reducing dangerous behaviour. 

It  is  estimated  to  result  in  1,153  lives  saved  and 
the 
injuries  avoided  over 
11,020 
2025-2050 horizon, relative to the baseline.  

serious 

204 https://www.roadsafetysweden.com/contentassets/b37f0951c837443eb9661668d5be439e/stockholm-declaration-english.pdf 

93 

 
 
 
 
 
 
 
 
 
 
 
                                                 
ANNEX 4: ANALYTICAL METHODS 

1. DESCRIPTION OF THE ANALYTICAL METHODS USED  

the  baseline  scenario  for 

the 
The  main  model  used  for  developing 
PRIMES-TREMOVE transport model by E3Modelling, a specific module of the PRIMES models. 
The model has a successful record of use in the Commission's energy, transport and climate policy 
assessments. In particular, it has been used for the impact assessments underpinning the “Fit for 55” 
package205,  the  impact  assessments  accompanying  the  2030  Climate  Target  Plan206  and  the  Staff 
Working  Document  accompanying 
the 
Commission’s proposal for a Long Term Strategy208 as well as for the 2020 and 2030 EU’s climate 
and energy policy framework.  

the  Sustainable  and  Smart  Mobility  Strategy207, 

initiative 

this 

is 

For the assessment of the impacts of the policy options an excel-based tool has been developed by 
COWI, Ecorys and NTUA in the context of the impact assessment support study209. The tool draws 
on the Standard Cost Model for the assessment of the costs and also includes an assessment of the 
impacts on road safety. The excel-based tool builds on data from the CARE database, the analysis of 
stakeholders' feedback and desk research undertaken in the context of the impact assessment support 
study.  The  proposed  measures  which  involve  the  amendment  of  the  Directive  are  assumed  to  be 
implemented  from  2025  onwards,  so  that  the  assessment  has  been  undertaken  for  the  2025-2050 
period and refers to  EU27. Costs and benefits  are expressed as present  value over the 2022-2050 
period, using a 3% discount rate. 

PRIMES-TREMOVE model  

The  PRIMES-TREMOVE  transport  model  projects  the  evolution  of  demand  for  passengers  and 
freight transport, by transport mode, and transport vehicle/technology, following a formulation based 
on microeconomic foundation of decisions of multiple actors. Operation, investment and emission 
costs, various policy measures, utility factors and congestion are among the drivers that influence the 
projections of the model. The projections of activity, equipment (fleet), usage of equipment, energy 
consumption and emissions (and other externalities) constitute the set of model outputs.  

The  PRIMES-TREMOVE  transport  model  can  therefore  provide  the  quantitative  analysis  for  the 
transport sector in the EU, candidate and neighbouring countries covering activity, equipment, energy 
and  emissions.  The  model  accounts  for  each  country  separately  which  means  that  the  detailed 
long-term outlooks are available both for each country and in aggregate forms (e.g. EU level). 

In the transport field, PRIMES-TREMOVE is suitable for modelling soft measures (e.g. eco-driving, 
labelling);  economic  measures  (e.g.  subsidies  and  taxes  on  fuels,  vehicles,  emissions;  ETS  for 
transport  when  linked  with  PRIMES;  pricing  of  congestion  and  other  externalities  such  as  air 
pollution, accidents and noise; measures supporting R&D); regulatory measures (e.g. CO2 emission 
performance standards for new light duty vehicles and heavy duty vehicles; EURO standards on road 
transport  vehicles;  technology  standards  for  non-road  transport  technologies,  deployment  of 
Intelligent Transport Systems) and infrastructure policies for alternative fuels (e.g. deployment of 

205  Delivering the European Green Deal | European Commission (europa.eu) 
206  SWD(2020)176 final. 
207  EUR-Lex - 52020SC0331 - EN - EUR-Lex (europa.eu)  
208  Source: 2050 long-term strategy (europa.eu)   
209  The analysis in this section is based on the COWI et al. (2022), Impact assessment support study for the revision of the directive 

on driving licences, and on the analysis of stakeholders' feedback. 

94 

 
                                                 
refuelling/recharging  infrastructure  for  electricity,  hydrogen,  LNG,  CNG).  Used  as  a  module  that 
contributes to the PRIMES energy system model, PRIMES-TREMOVE can show how policies and 
trends in the field of transport contribute to economy-wide trends in energy use and emissions. Using 
data  disaggregated  per  Member  State,  the  model  can  show  differentiated  trends  across  Member 
States.  

The  PRIMES-TREMOVE  has  been  developed  and  is  maintained  by  E3Modelling,  based  on,  but 
extending features of, the open source TREMOVE model developed by the TREMOVE210 modelling 
community.  Part  of  the  model  (e.g.  the  utility  nested  tree)  was  built  following  the  TREMOVE 
model.211 Other parts, like the component on fuel consumption and emissions, follow the COPERT 
model. 

Data inputs 

The main data sources for inputs to the PRIMES-TREMOVE model, such as for activity and energy 
consumption, come from EUROSTAT databases and from the Statistical Pocketbook "EU transport 
in figures212. Excise taxes are derived from DG TAXUD excise duty tables. Other data comes from 
different sources such as research projects (e.g. TRACCS project) and reports. 

In the context of this exercise, the PRIMES-TREMOVE transport model is calibrated to 2005, 2010 
and 2015 historical data. Available data on 2020 market shares of different powertrain types have 
also been taken into account. 

2. BASELINE SCENARIO 

In  order  to  reflect  the  fundamental  socio-economic,  technological  and  policy  developments,  the 
Commission  prepares  periodically  an  EU  Reference  Scenario  on  energy,  transport  and  GHG 
emissions.  The  socio-economic  and  technological  developments  used  for  developing  the  baseline 
scenario for this impact assessment build on the latest “EU Reference scenario 2020” (REF2020)213. 
The same assumptions have been used in the policy scenarios underpinning the impact assessments 
accompanying the “Fit for 55” package214.  

2.1.  Main assumptions of the Baseline scenario 

The main assumptions related to economic development, international energy prices and technologies 
are described below. 

210  Source: https://www.tmleuven.be/en/navigation/TREMOVE    
211  Several model enhancements were made compared to the standard TREMOVE model, as for example: for the number of vintages 
(allowing  representation  of  the  choice  of  second-hand  cars);  for  the  technology  categories  which  include  vehicle  types  using 
electricity from the grid and fuel cells. The model also incorporates additional fuel types, such as biofuels (when they differ from 
standard fossil fuel technologies), LPG, LNG, hydrogen and e-fuels. In addition, representation of infrastructure for refuelling and 
recharging are among the model refinements, influencing fuel choices. A  major model enhancement concerns the inclusion of 
heterogeneity in the distance of stylised trips; the model considers that the trip distances follow a distribution function with different 
distances and frequencies. The inclusion of heterogeneity was found to be of significant influence in the choice of vehicle-fuels 
especially for vehicles-fuels with range limitations. 

212  Source: https://ec.europa.eu/transport/facts-fundings/statistics_en   
213  EU Reference Scenario 2020 (europa.eu) 
214  Policy scenarios for delivering the European Green Deal (europa.eu) 

95 

 
                                                 
2.1.1.  Economic assumptions  

The modelling work is based on socio-economic assumptions describing the expected evolution of 
the European society.  Long-term projections on population  dynamics and economic activity form 
part of the input to the model and are used to estimate transport activity, particularly relevant for this 
impact assessment.  

Population  projections  from  Eurostat215  are  used  to  estimate  the  evolution  of  the  European 
population, which is expected to change little in total number in the coming decades. The GDP growth 
projections  are  from  the  Ageing  Report  2021216  by  the  Directorate  General  for  Economic  and 
Financial Affairs, which are based on the same population growth assumptions. 

Table 12: Projected population and GDP growth per Member State 

Population 

GDP growth 

EU27 

Austria 

Belgium 

Bulgaria 

Croatia 

Cyprus 

Czechia 

Denmark 

Estonia 

Finland 

France 

Germany 

Greece 

Hungary 

Ireland 

Italy 

Latvia 

Lithuania 

Luxembourg 

Malta 

Netherlands 

Poland 

Portugal 

Romania 

Slovakia 

Slovenia 

Spain 

Sweden 

2020 
447.7 

8.90 

11.51 

6.95 

4.06 

0.89 

10.69 

5.81 

1.33 

5.53 

67.20 

83.14 

10.70 

9.77 

4.97 

60.29 

1.91 

2.79 

0.63 

0.51 

17.40 

37.94 

10.29 

19.28 

5.46 

2.10 

47.32 

10.32 

2025 
449.3 

9.03 

11.66 

6.69 

3.94 

0.93 

10.79 

5.88 

1.32 

5.54 

68.04 

83.48 

10.51 

9.70 

5.27 

60.09 

1.82 

2.71 

0.66 

0.56 

17.75 

37.57 

10.22 

18.51 

5.47 

2.11 

48.31 

10.75 

2030 
449.1 

9.15 

11.76 

6.45 

3.83 

0.96 

10.76 

5.96 

1.31 

5.52 

68.75 

83.45 

10.30 

9.62 

5.50 

59.94 

1.71 

2.58 

0.69 

0.59 

17.97 

37.02 

10.09 

17.81 

5.44 

2.11 

48.75 

11.10 

2020-‘25 
0.9% 

2026-‘30 
1.1% 

0.9% 

0.8% 

0.7% 

0.2% 

0.7% 

1.6% 

2.0% 

2.2% 

0.6% 

0.7% 

0.8% 

0.7% 

1.8% 

2.0% 

0.3% 

1.4% 

1.7% 

1.7% 

2.7% 

0.7% 

2.1% 

0.8% 

2.7% 

1.1% 

2.1% 

0.9% 

1.4% 

1.2% 

0.8% 

1.3% 

0.6% 

1.7% 

2.0% 

1.7% 

2.6% 

1.2% 

1.0% 

0.7% 

0.6% 

2.6% 

1.7% 

0.3% 

1.9% 

1.5% 

2.0% 

4.1% 

0.7% 

2.4% 

0.8% 

3.0% 

1.7% 

2.4% 

1.6% 

2.2% 

215  EUROPOP2019 population projections: Eurostat - Data Explorer (europa.eu)   
216  The  2021  Ageing  Report :  Underlying  assumptions  and  projection  methodologies  The  2021  Ageing  Report:  Underlying 

Assumptions and Projection Methodologies | European Commission (europa.eu)   

96 

 
 
  
                                                 
Beyond the update of the population and growth assumptions, an update of the projections on the 
sectoral composition of GDP was also carried out using the GEM-E3 computable general equilibrium 
model.  These  projections  take  into  account  the  potential  medium-  to  long-term  impacts  of  the 
COVID-19 crisis on the structure of the economy, even though there are inherent uncertainties related 
to its eventual impacts. Overall, conservative assumptions were made regarding the medium-term 
impacts  of  the  pandemic  on  the  re-localisation  of  global  value  chains,  teleworking  and 
teleconferencing and global tourism. 

2.1.2.  International energy prices assumptions  

Alongside socio-economic projections, transport modelling requires projections of international fuel 
prices.  The  projections  of  the  POLES-JRC  model  –  elaborated  by  the  Joint  Research  Centre  and 
derived  from  the  Global  Energy  and  Climate  Outlook  (GECO217)  –  are  used  to  obtain  long-term 
estimates of the international fuel prices. The table below shows the oil prices assumptions of the 
baseline and policy options of this impact assessment.  

Table 13: Oil price assumptions  

in $'15 per boe 
Oil 

in €'15 per boe 
Oil 

2015 
52.3 

2015 
47.2 

2020 
39.8 

2020 
35.8 

2030 
80.1 

2030 
72.2 

2040 
97.4 

2040 
87.8 

2050 
117.9 

2050 
106.3 

Source: Derived from JRC, POLES-JRC model, Global Energy and Climate Outlook (GECO) 

2.1.3.  Technology assumptions 

Modelling scenarios are highly dependent on the assumptions on the development of technologies, 
both  in  terms  of performance and  costs. For the  purpose of the impact  assessments  related to  the 
“Climate Target Plan” and the “Fit for 55” policy package, these assumptions have been updated 
based on a rigorous literature review carried out  by external  consultants in  collaboration with  the 
JRC218.  Continuing  the  approach  adopted  in  the  long-term  strategy  in  2018,  the  Commission 
consulted  on  the  technology  assumption  with  stakeholders  in  2019.  In  particular,  the  technology 
database of the PRIMES and PRIMES-TREMOVE models (together with GAINS, GLOBIOM, and 
CAPRI) benefited from a dedicated consultation workshop held on 11th November 2019. EU Member 
States representatives also had the opportunity to comment on the cost elements during a workshop 
held on 25th November 2019. The updated technology assumptions are published together with the 
EU Reference Scenario 2020219. The same assumptions have been used in the context of this impact 
assessment. 

2.1.4.  Policies in the Baseline scenario  

Building on the EU Reference scenario 2020, the baseline scenario for this impact assessment has 
been  designed  to  include  the  initiatives  of  the  ‘Fit  for  55’  package220.  It  also  assumes  the 
implementation  of  the  General  Safety  Regulation  (Regulation  (EU)  2019/2144).  The  Baseline 
scenario assumes no further EU level intervention beyond the current DL Directive.  

217  https://ec.europa.eu/jrc/en/geco   
218  JRC118275  
219  EU Reference Scenario 2020 (europa.eu) 
220  Delivering the European Green Deal | European Commission (europa.eu) 

97 

 
                                                 
 
 
 
 
 
 
2.2.  Baseline scenario results 

Evolution of the number of fatalities and injuries. In the baseline scenario, the number of fatalities 
is projected to decrease by 23% by 2030 relative to 2015 and by 30% by 2050 relative to 2015221. 
The number of serious and slight injuries is projected to decrease at lower rate (by 18% between 2015 
and 2030 and by 25% for 2015-2050). This is despite the increase in traffic over time. Relative to 
2020, that reflects the impact of the COVID-19 pandemic, the number of fatalities and slight injuries 
is projected to decrease by 3% by 2030 while the number of serious injuries is projected to remain 
relatively stable. By 2050, the number of fatalities would be 13% lower relative to 2020 while the 
number of serious injuries would be 10% lower and that of slight injuries 11% lower. In particular, 
the number of fatalities in which novice drivers driving a car are involved are projected to increase 
by  3%  by  2030  (at  around  3,900)  and  to  decrease  at  around  3,400  by  2050  (10%  decrease  for 
2020-2050).  This  is because, despite the  fact that novice drivers  are more prone to accidents, the 
ageing of the population will lead to a decrease in the share of young drivers in the overall driver’s 
population. In the baseline scenario, the targets of the EU Road Safety Policy Framework 2021-2030 
– Next steps towards “Vision Zero”, of reducing the number of road deaths by 50% between 2020 
and 2030 as well as reducing the number of serious injuries by 50% in the same period, would not be 
met. In addition, this is still far from the goal of the Sustainable and Smart Mobility Strategy of close 
to zero death toll for all modes of transport in the EU by 2050. 

Evolution of the number of theoretical and practical driving tests and costs. In the baseline scenario, 
the number of theoretical and practical driving tests is projected to increase by 7% by 2030 (from 
21.2 million in 2019 to 22.7 million in 2030) and by 12% by 2050 (at around 23.8 million), relative 
to 2019. The number of theoretical and practical driving tests for category B licence is driven by the 
projected evolution of the population above 15 years old222 and the evolution of the vehicle stock 
over  time,  while  the  number  of  theoretical  and  practical  driving  tests  for  categories  A,  C  and  D 
licences are driven by the projected evolution of the vehicle stock. The projected evolution of the 
total number of theoretical and practical driving tests, by Member State, in the baseline scenario is 
provided in Table 14.  

Table 14: Projected evolution of the total number of theoretical and practical driving tests, by Member State, in 
the baseline scenario (in millions) 

2019 

2030 

2050 

Austria 
Belgium 
Bulgaria 
Cyprus 
Croatia 
Czech Republic 
Denmark 
Estonia 
Finland 
France 
Germany 
Greece 
Hungary 
Ireland 
Italy 

0.34 
0.71 
0.27 
0.05 
0.23 
0.51 
0.22 
0.06 
0.27 
3.57 
3.47 
0.36 
0.29 
0.33 
1.77 

0.39 
0.87 
0.27 
0.05 
0.24 
0.58 
0.25 
0.07 
0.29 
4.09 
3.32 
0.42 
0.33 
0.36 
1.96 

0.42 
0.92 
0.28 
0.06 
0.25 
0.70 
0.25 
0.07 
0.27 
4.28 
3.56 
0.43 
0.37 
0.38 
2.03 

221  Projections refer to injuries in which a passenger vehicle, a light commercial vehicle, a bus or a truck is involved (power two 

wheelers are not included in the projections). 

222  The 2021 Ageing Report: Economic and Budgetary Projections for the EU Member States (2019-2070) (europa.eu) 

98 

 
 
                                                 
2019 

2030 

2050 

Latvia 
Lithuania 
Luxembourg 
Malta 
Netherlands 
Poland 
Portugal 
Romania 
Slovenia 
Slovakia 
Spain 
Sweden 
EU27 
Source: COWI, Ecorys and NTUA (2022), Impact assessment support study 

0.06 
0.23 
0.03 
0.02 
1.15 
1.94 
0.48 
1.35 
0.10 
0.19 
2.48 
0.76 
21.24 

0.05 
0.21 
0.03 
0.03 
1.15 
2.06 
0.50 
1.43 
0.09 
0.20 
2.59 
0.90 
22.74 

0.05 
0.25 
0.04 
0.03 
1.19 
1.90 
0.48 
1.51 
0.09 
0.22 
2.79 
0.97 
23.77 

The average cost for a theoretical test for a category B licence is estimated at EUR 38 (i.e. ranging 
between EUR 7 for Poland and EUR 110 for Portugal) and the one for the practical driving test at 
EUR 88, based on information obtained for 17 Member States in the context of the impact assessment 
support study. For category A licences, the average cost for the theoretical test is estimated at EUR 
37  and  for  the  practical  test  at  EUR  101.  For  category  C  and  D  licences,  the  average  cost  for  a 
theoretical test is estimated at EUR 42 and EUR 43, respectively, and for the practical test at EUR 
134 and EUR 136, based on data for 17 Member States. For the other Member States, the average 
cost for the 17 Member States has been used. The total costs at EU level associated to the theoretical 
and practical driving tests are projected to go up from EUR 1.47 billion in 2019 to EUR 1.55 billion 
in  2030  and  EUR  1.64  billion  by  2050,  driven  by  the  increase  in  the  number  of  theoretical  and 
practical driving tests (see Table 15). 

Table 15: Projected evolution of the total number of theoretical and practical driving tests, by Member State, in 
the baseline scenario (in millions) 

2019 

2030 

2050 

Austria 
Belgium 
Bulgaria 
Cyprus 
Croatia 
Czech Republic 
Denmark 
Estonia 
Finland 
France 
Germany 
Greece 
Hungary 
Ireland 
Italy 
Latvia 
Lithuania 
Luxembourg 
Malta 
Netherlands 
Poland 
Portugal 

14.3 
21.3 
17.4 
3.1 
14.8 
27.5 
14.2 
4.0 
19.4 
148.7 
252.1 
18.6 
18.8 
22.6 
154.2 
3.9 
7.3 
2.5 
1.6 
90.8 
37.7 
61.0 

16.5 
25.9 
17.3 
3.5 
15.9 
31.7 
15.9 
4.2 
20.7 
170.4 
243.2 
20.5 
20.9 
22.7 
176.4 
3.5 
6.5 
3.0 
1.8 
83.8 
40.1 
62.5 

17.7 
28.0 
18.3 
3.8 
16.2 
39.0 
16.1 
4.7 
19.4 
177.9 
264.9 
21.1 
23.8 
24.2 
184.4 
3.4 
8.1 
3.4 
2.2 
86.8 
37.6 
59.6 

99 

 
 
 
2019 

2030 

2050 

Romania 
Slovenia 
Slovakia 
Spain 
Sweden 
EU27 
Source: COWI, Ecorys and NTUA (2022), Impact assessment support study 

69.8 
4.1 
11.9 
387.9 
42.2 
1,471.6 

73.7 
3.6 
12.5 
407.8 
48.1 
1,552.5 

78.0 
3.6 
13.6 
441.4 
51.8 
1,648.9 

Evolution of the number of active driving licences and exchanged licences. The number of driving 
licences (A to D categories) is projected to increase by around 5% by 2030 relative to 2019 (from 
around 250 million in 2019 to 263 million licences in 2030) and to remain relatively stable by 2050 
(at around 260 million in 2050). Without further EU level action on the mutual recognition of the 
mobile driving licences, the physical licences are projected to remain dominant in the EU by 2050. 
Indeed, while most of the Member States are likely to implement mobile driving licences, they will 
remain valid only on the territory of the State issuing them. To travel abroad within the EU, drivers 
will still have to keep their physical driving licences. 

2050 

2030 

2019 

Table  16:  Projected  evolution  of  the  number  of  active  licences,  by  Member  State,  in  the  baseline  scenario  (in 
millions) 
in million 
Austria 
Belgium 
Bulgaria 
Cyprus 
Croatia 
Czech Republic 
Denmark 
Estonia 
Finland 
France 
Germany 
Greece 
Hungary 
Ireland 
Italy 
Latvia 
Lithuania 
Luxembourg 
Malta 
Netherlands 
Poland 
Portugal 
Romania 
Slovenia 
Slovakia 
Spain 
Sweden 
EU27 
Source: COWI, Ecorys and NTUA (2022), Impact assessment support study 

5.5 
6.9 
3.3 
0.6 
2.0 
6.1 
3.5 
0.7 
3.7 
40.3 
42.5 
5.7 
5.4 
3.8 
38.4 
0.7 
1.2 
0.5 
0.4 
12.2 
21.4 
6.3 
6.7 
1.2 
3.6 
28.8 
8.2 
259.7 

5.4 
6.8 
3.8 
0.6 
2.3 
6.2 
3.4 
0.8 
3.9 
39.4 
42.7 
6.2 
5.6 
3.3 
39.7 
0.8 
1.4 
0.4 
0.3 
12.0 
22.9 
6.8 
7.6 
1.2 
3.7 
28.5 
7.4 
263.1 

5.0 
6.3 
4.0 
0.5 
2.3 
5.9 
3.2 
0.7 
3.8 
36.3 
40.1 
6.1 
5.5 
2.8 
38.2 
0.9 
1.5 
0.3 
0.3 
11.4 
22.0 
6.6 
7.7 
1.2 
3.6 
26.9 
6.7 
249.6 

The number of EU exchanged licences would increase by 3% by 2030 and 4% by 2050, while the 
number of third country exchanged licences are projected to go up by 2% by 2030 and 7% by 2050 

100 

 
 
(see Table 17). Without further EU level intervention, holders of foreign driving licences (including 
EU  citizens)  will  likely  continue  to  see  their  driving  rights  limited.  Indeed,  the  restrictions  when 
moving to another Member State will remain applicable to them. 

Table 17: Projected evolution of the total number of exchanges at EU level in the baseline scenario (in millions) 
'19-'50 

'19-'30 

2019 
0.77 
0.35 
0.42 

2030 
0.79 
0.36 
0.43 

2050 
0.81 
0.37 
0.44 

2% 
3% 
2% 

5% 
4% 
7% 

Exchanges 

EU exchanges 
Third countries exchanges 

Source: COWI, Ecorys and NTUA (2022), Impact assessment support study 

3. IMPACTS BY POLICY MEASURE ON COSTS 

This  section  explains  the  inputs  used  and  provides  the  assessment  of  the  impacts  of  the  policy 
measures included in the policy options on costs. The synergies between the measures included in 
the options are already captured in this section.  

PMc1: Update of standards on skills and knowledge to be met for the first issuance of a driving 
licence 

Adjustment costs for citizens 

PMc1 foresees to extend the range of issues subject to testing, including knowledge of new vehicle 
features  (safe  use  of  Advanced  Driving  Assistance  System/automation)  as  well  as  perception  of 
hazardous situations, understanding of risk factors in normal traffic situations (including the presence 
of new vulnerable road users such as e-scooters) and safety of zero emission vehicles (e.g. chemical 
and explosion risks in the event of fire affecting an electric vehicle). 

The  measure  would  likely  result  in  adjustment  costs  for  applicants  for  a  B-licence,  especially 
concerning the theoretical test. This is because applicants are to be tested on more subjects and this 
may result in fewer passing the test, with the need to retake the test. Especially the Hazard Perception 
Test (HPT) that is conducted separately from a theoretical test is likely to result in fewer passing the 
exam. Belgium, Germany, Finland and the Netherlands have already introduced the HPT and they 
are assumed to continue to implement it in the baseline scenario.  

Flanders introduced the Hazard Perception Test in June 2017. During 2018-2020, about 80% of the 
candidates passed the Hazard Perception Test (77% in 2017, 81% in 2018 and 80% in 2019). The 
Netherlands revised the theoretical testing framework in 2019 and improved the Hazard Perception 
Test element (e.g. by making use of video instead of pictures). There was however no clear impact 
on the passing rate of theoretical exams. The passing rate for the theoretical exam increased from 
41% in 2019 to 43% in 2020, to drop to 38% in 2021.  

It  is  difficult  to  relate  the  passing  rate  of  the  Hazard  Perception  Test  to  the  passing  rate  of  the 
theoretical exam. The question is whether the candidates that fail the Hazard Perception Test also fail 
other parts of the theoretical exam. If this is the case, the introduction of HPT would not affect passing 
rates; people that do not pass the HPT would not have passed the theoretical exam in the baseline 
scenario. The other extreme, in which only candidates that passed other parts of the exam fail the 
HPT, results in larger impacts. In this situation, it is estimated that the passing rate would drop by 
20% based on experience in Flanders. On the other hand, data from the Netherlands suggests that the 
HPT  is  mainly  failed  by  candidates  that  would  have  also  failed  the  exam  if  the  HPT  was  not 
introduced (since there was no clear impact  on average passing rates for theoretical exams). Data 
from Belgium, on the passing rates of theoretical exams, suggests a similar dynamic. The passing 

101 

 
 
rate for the theoretical B-exam decreased from 40% in 2017 to 39% in 2018 and increased to 44% in 
2020 and 40% in 2021. 

Other elements of the measure, such as testing on advanced drivers’ assistance systems, may also 
lead to a decrease in the passing rates for the theoretical exams. This is because the test may become 
more difficult and capture more elements, especially on the theoretical part. The decrease in passing 
rates translates in an increase in (re-)testing relative to the baseline. 

Considering all these effects, it is estimated that PMc1 would thus lead to an increase by 74,174 of 
the theoretical tests in 2030 and 75,382 in 2050, assuming a 1% drop in passing rates relative to the 
baseline.  The  average  cost  for  a  theoretical  exam  is  estimated  at  38  EUR,  based  on  information 
obtained for 17 Member States (i.e. ranging between 7 EUR for Poland to 110 for Portugal). For the 
other Member States, the average cost for a theoretical exam has been used for estimating the costs. 
The adjustment costs for applicants for a B-licence are estimated at EUR 2.8 million in 2030 and 
EUR 2.9 million  in  2050 relative to the baseline. Expressed as present  value over the 2025-2050 
period, the adjustment costs for citizens in PMc1 are estimated at EUR 52.5 million relative to the 
baseline (in 2021 prices). The costs of PMc1 are the same in all policy options.  

Adjustment costs for Member States administrations  

For the development of the Hazard Perception Test, new testing material would need to be developed. 
In PMc1 it is assumed that all Member States that do not have an HPT component in their testing 
framework (i.e. all except Belgium, Germany, Finland and the Netherlands) would need to develop 
some (animated) videos. The cost for the production of the video is estimated at around EUR 7,000 
per minute on average at EU level and the animated video is assumed to  require 30 minutes. The 
animated video is assumed to be produced every 5 years starting from 2025. The adjustment costs 
for Member States authorities are estimated at EUR 3.5 million in 2030 and in 2050 relative to the 
baseline. Expressed as present value over the 2025-2050 period, the adjustment costs for Member 
States authorities are estimated at EUR 15.2 million relative to the baseline (in 2021 prices). The 
costs of PMc1 are the same in all policy options.  

Other elements of PMc1, aiming to update the standards on skills and knowledge, are not expected 
to lead to adjustment costs for Member States authorities. During the stakeholders’ consultation, it 
was  acknowledged  that  theoretical  tests  are  often  revised  (e.g.  questions  are  removed  and  others 
added). Thereby, they are not expected to result in additional costs relative to the baseline. 

PMc2: Introduction of rules to remove restrictions associated to automatic gear transmission 

Administrative costs savings for citizens  

Restrictions related to transmission gear will be adapted to reflect the increased uptake of electric 
vehicles. Without compromising road safety, these adaptations will make it simpler to remove the 
restriction applied to driving licences when passing the driving test on a vehicle with an automatic 
gear  transmission  (a  short  practical  test,  potentially  on  simulator,  or  a  certified  training  will  be 
required instead of the full practical test currently required). 

Germany  has  implemented  this  measure  since  January  2021  and  it  is  assumed  to  continue  to 
implement it in the baseline scenario. The assumptions used for assessing the impacts of this measure 
draw on the impact assessment that supported the decision-making in Germany for implementing the 

102 

 
measure223. In the impact assessment it is argued that the measure might have different impacts for 
driving licence applicants. On the one hand, it would be easier to learn how to drive in a vehicle with 
an automatic transmission. As such, fewer lessons may be needed and thereby the costs of obtaining 
a B-licence may decrease. On the other hand, by requiring a minimal number of training hours in a 
vehicle with automatic gear, the training requirements would be higher relative to the baseline and 
the training costs may increase. The impact assessment concluded that overall these two effects would 
balance out. 

PMc2 is expected to only affect holders of a Code 78 licence224 that would like to have this code 
removed. In the baseline scenario, the number of practical tests for a Code 78 licence is projected to 
increase  to  1.6  million  at  EU  level  by  2030  and  8.1  million  by  2050,  driven  by  the  uptake  of 
zero-emission  vehicles  with  automatic  transmission.  In  Germany,  some  450  tests  are  conducted 
annually to have Code 78 removed. This represents around 0.9% of the Code 78 tests225. In PMc2 the 
number of practical tests for removing the Code 78 licence would decrease by 0.9% in 2025, 0.1% 
in 2030 and 0% by 2050 relative to the baseline. The reduction is lower post-2025 because of the 
increasing share of vehicles with automatic transmission and thus the limited need to be able to drive 
a vehicle with manual transmission. PMc2 results in a decrease in the number of practical tests at EU 
level by 1,019 in 2030 and 714 in 2050 relative to the baseline.  

The administrative costs savings for citizens are estimated at EUR 0.09 million in 2030 and EUR 
0.07 million in 2050 relative to the baseline. Expressed as present value over the 2025-2050 period, 
they are estimated at EUR 2.3 million relative to the baseline (in 2021 prices). The costs savings for 
citizens of PMc2 are the same in all policy options. 

Impacts on the private sector (driving schools)  

There are no costs associated to PMc2 for driving schools. In the baseline scenario, the progressive 
uptake of zero-emission vehicles imply the uptake of vehicles with automatic transmission by default. 
Thereby,  the  demand  for  Code  78  licences  and  Code  78  tests  is  projected  to  increase  (i.e.  to  1.6 
million tests in 2030 and 8.1 million tests in 2050) in the baseline, since the need to be able to drive 
a vehicle with manual transmission would decrease.  

PMc3: Amendments to the definitions of vehicle categories for cars and vans (maximum mass) 

In  PMc3,  category  B  licence  will  include  alternatively-fuelled  vehicles  of  a  maximum  mass  not 
exceeding 4,25t, without a trailer. This measure is expected to have a positive impact on citizens, by 
allowing them to drive such vehicles with a category B licence. It would also have an indirect positive 
effect on manufacturers of B category vehicles. PMc3 is not expected to have a significant impact on 
costs.  

PMc4: Improvement of RESPER for the purpose of enforcement 

Adjustment costs for Member States administrations  

Improvements to RESPER (the network for the exchange of information related to driving licences) 
will be introduced to further support cooperation between issuing authorities and thereby ensuring a 

223  https://www.bundesrat.de/SharedDocs/drucksachen/2020/0501-0600/579-20.pdf?__blob=publicationFile&v=1  
224  EU Code 78 imposes a restriction on the holder of the licence, in the sense that they can only drive a  vehicle  with automatic 

transmission. 

225  https://www.bundesrat.de/SharedDocs/drucksachen/2020/0501-0600/579-20.pdf?__blob=publicationFile&v=1  

103 

 
                                                 
better fight against fraud and dangerous behaviour. It will address the practical difficulties related to 
privacy protection resulting from the Directive (EU) 2018/645, by clarifying the use cases and with 
a strong focus on fundamental rights. In addition, the needs of law enforcement will be better covered 
in  term  of  data  quality  and  reactivity  as  well  as  with  the  inclusion  of  information  on  driving 
disqualifications of non-residents226. 

All  Member  States  are  already  using  the  RESPER  system  for  the  exchange  of  information.  The 
ex-post  evaluation227  indicated  that  Member  States  favour  the  use  of  RESPER  for  enforcement 
purposes. However, some Member States indicated that the data quality is often low. Both findings 
were  confirmed  during  a  stakeholders’  workshop  organised  on  19  May  2022,  during  the  targeted 
interviews and the targeted survey organised in the context of the impact assessment support study228. 

Some technical modifications would be needed to ensure that RESPER is able to exchange additional 
elements, mainly related to driving disqualifications. It should be noted however, that overall, these 
costs are likely not to be substantial. In the assessment, a conservative assumption has been made in 
which  all  Member  States  are  faced  with  one-off  adjustment  costs  of  EUR  50,000  relative  to  the 
baseline, bringing the total one-off costs for the EU27 at EUR 1.350 million in 2025.  

PMc4  also  supports  the  implementation  of  other  policy  measures  included  in  the  options.  For 
example, enforcement authorities would benefit from access to the system to check the validity of a 
digital driving licence (PMc9). The mutual recognition of driving disqualifications (PM4) would also 
be facilitated by the exchange of information via RESPER.  

PMc5: Update of standards on physical and mental fitness to be met for the issuance of driving 
licences  

Adjustment costs savings for citizens 

In PMc5 the requirements related to diabetes would be updated taking into account the evolution of 
medical care for this disease. In particular, the frequency of the physical fitness assessment will be 
of 10 years instead of 5.  

According to an OECD study229, in 2019 about 32.3 million adults were diagnosed with diabetes in 
the EU. Around 66% of the population above 15 years old is in possession of a driving licence. The 
number  of  adults  diagnosed  with  diabetes  that  hold  a  driving  licence  is  estimated  at  around  21.3 
million, or 8.5% of the total number of active driving licences in 2019. Assuming that the share of 
adults diagnosed with diabetes would remain constant over time in the baseline scenario, the number 
of driving licences held by people diagnosed with diabetes is projected to increase to 22.7 million by 
2030  and  slightly  decrease  to  21.8  million  by  2050.  In  the  baseline  scenario,  in  line  with  the 
requirements of the Directive, people diagnosed with diabetes need to undertake a physical fitness 
check every five years.  Thus, the number of physical fitness checks is estimated at 4.3 million in 
2019, 4.5 million in 2030 and 4.4 million in 2050 in the baseline scenario.  

In PMc5, the frequency of the physical fitness assessment is increased to ten years. As a result, the 
number of physical fitness checks for people suffering from diabetes is estimated to decrease by 2.3 
million  in  2030  and  2.2  million  in  2050  relative  to  the  baseline.  Based  on  data  available  for  23 

226  Member States will be then able to decide if and how they apply or not disqualification to the offender. 
227  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/2022/0017 final. 

228  COWI et al. (2022), Impact assessment support study for the revision of the directive on driving licences 
229  https://www.oecd-ilibrary.org/sites/83231356-en/index.html?itemId=/content/component/83231356-en  

104 

 
                                                 
Member States, the average cost per medical check is estimated at 47 EUR. For Member States for 
which the cost per medical check is not available (BG, CY, MT, PT) the average cost of 47 EUR per 
medical check has been assumed.  

The adjustment costs savings for citizens is estimated at EUR 136 million in 2030 and EUR 130.3 
million in 2050 relative to the baseline. Expressed as present value over the 2025-2050 period, they 
are estimated at EUR 2.477 million relative to the baseline (in 2021 prices). The costs savings for 
citizens of PMc5 are the same in all policy options. 

The estimated reduction in the number of physical fitness checks and the reduction in costs relative 
to the baseline, by Member State, is provided in Table 18. 

Table 18: Reduction in the number of physical fitness checks and costs (in million EUR) in PMc5 relative to the 
baseline 

Reduction in the number of physical 
fitness checks 

Reduction in costs for physical fitness 
checks (in million EUR) 

Austria 
Belgium 
Bulgaria 
Cyprus 
Croatia 
Czech Republic 
Denmark 
Estonia 
Finland 
France 
Germany 
Greece 
Hungary 
Ireland 
Italy 
Latvia 
Lithuania 
Luxembourg 
Malta 
Netherlands 
Poland 
Portugal 
Romania 
Slovenia 
Slovakia 
Spain 
Sweden 
EU27 
Source: COWI, Ecorys and NTUA (2022), Impact assessment support study  

2030 
46,410 
60,116 
32,124 
4,829 
19,308 
53,766 
29,115 
6,567 
27,657 
343,554 
367,529 
53,642 
48,296 
25,275 
344,956 
6,937 
9,965 
3,544 
2,998 
109,123 
195,993 
59,414 
65,077 
10,791 
32,498 
250,010 
64,169 
2,273,662 

2050 
46,991 
60,753 
26,699 
5,229 
16,216 
50,316 
29,483 
6,183 
24,788 
350,908 
348,537 
46,846 
44,920 
28,179 
329,163 
5,523 
6,940 
3,987 
3,454 
110,544 
172,871 
54,058 
51,942 
10,255 
30,342 
248,049 
70,708 
2,183,889 

2030 
1.6  
4.4  
1.5  
0.2  
0.8  
1.1  
1.6  
0.3  
3.7  
12.4  
49.6  
1.1  
0.4  
1.3  
20.7  
0.3  
0.2  
0.2  
0.1  
4.5  
8.3  
2.8  
1.8  
0.6  
0.5  
15.0  
0.9  
136.0 

2050 
1.6  
4.4  
1.3  
0.2  
0.7  
1.0  
1.6  
0.2  
3.3  
12.6  
47.1  
0.9  
0.4  
1.4  
19.7  
0.2  
0.2  
0.2  
0.2  
4.6  
7.3  
2.6  
1.4  
0.6  
0.5  
14.9  
1.0  
130.3 

PMc6: New rules on the use of technologies to offset medical unfitness 

In PMc6, when a person does not meet the standards on physical and mental fitness, a driving licence 
may be issued to that person with the obligation to use a technology that mitigates the unfitness to 
drive (e.g. alcohol interlock). 

105 

 
  
In the baseline, drivers that are diagnosed with ‘alcohol-dependence’ are not entitled to drive a vehicle 
(Annex III.14). A paper by Rehm at al. (2015)230 estimated that some 3% of EU citizens in the age 
group  18  to  64  suffer  from  alcohol  dependence.  With  new  intelligent  devices  such  as  alcohol 
interlock, a driver should repeatedly  proof that he/she is  not  under the influence of alcohol when 
driving a vehicle. This could facilitate people with alcohol dependence to drive a vehicle equipped 
with  an  alcohol  interlock,  which  could  have  a  positive  effect  on  the  free  movement  of  people 
diagnosed with alcohol-dependence. However, they will have to bear the costs of installing the device 
in  the  vehicle.  In  the  Netherlands,  the  full  costs  (installation,  administrative  costs,  costs  for 
monitoring and support) for an alcohol interlock are  estimated at  EUR 200 per month231 or EUR 
2,400  per  year  driver.  There  is  no  evidence  on  the  number  of  people  that  suffer  from  alcohol 
dependence that would be willing to install an alcohol interlock. For this reason, the costs related to 
this measure are not quantified. PMc6 is included in all policy options and the potential costs would 
be the same, not affecting the ranking of the options.   

PMc7: Establishment of a knowledge management Platform for authorities regarding physical 
and mental fitness to drive 

Adjustment costs for the European Commission 

In PMc7 an expert group will be established and annual meetings will be organised by the European 
Commission,  to  allow  authorities  to  share  information  and  best  practices  in  relation  physical  and 
mental  fitness  to  drive (e.g. screening,  assessment). The cost  of organising one meeting per  year, 
including the reimbursement of participants, is estimated at EUR 30,000 per year from 2025 onwards. 
Expressed  as  present  value  over  the  2025-2050  period,  the  adjustment  costs  for  the  European 
Commission are estimated at EUR 0.6 million relative to the baseline (in 2021 prices). The costs of 
PMc7 are the same in all policy options. 

PMc8: Clarification of the concept of normal residence 

In PMc8 the concept  of  normal  residence will be developed to  specify how the normal  residence 
should be determined during the 6 first months of establishment in a new country, including certain 
special cases where two or more Member States consider they can be issuing authority. 

The number of EU exchanges of driving licences is estimated at some 0.3 million cases in 2019 and 
projected at around 0.2 million by 2030 and 2050 in the baseline scenario. The number of cases where 
normal residence cannot be established is fairly small at EU level. However, although the number of 
cases is low, the consequences for individuals can be significant. For example, the right to drive a 
vehicle (e.g. issuance of a licence) might not be granted if no country recognises the normal residence 
of an individual, which significantly impairs the free movement of these road users. This was also 
highlighted during the stakeholders’ consultation. 

The  clarification  of  the  concept  of  normal  residence  is  expected  to  have  a  positive  impacts  costs 
related to handling of complaints from citizens and in extreme cases, court rulings. They are also 
expected  to  result  in  a  reduction  of  the  hassle  costs  for  citizens.  However,  it  was  not  possible  to 
quantify the reduction in costs. PMc8 is included in all policy options and the potential cost savings 
would be the same, not affecting the ranking of the options. 

230   https://pubmed.ncbi.nlm.nih.gov/25342593/  
231  https://etsc.eu/wp-content/uploads/2016_12_alcohol_interlock_guidelines_final.pdf  

106 

 
                                                 
PMc9: Introduction of the EU mobile driving licence 

In PMc9 an EU digital driving licence is assumed to be introduced, based on ISO18013-5 and on 
eIDAS features. Mobile driving licences would be recognised from 2026 and would be issued by 
default from 2028. 

Adjustment costs for Member States administrations 

The introduction of the EU mobile driving licence (PMc9) requires the development of an IT system 
for the mobile driving licences. The estimation of the costs is based on the following architecture, 
which adheres to the ISO standard and assumes the use of the EU Identity Wallet.  

Figure 4: Architecture for establishing a system for mobile driving licences 

Source: COWI, Ecorys and NTUA (2022), Impact assessment support study 

The cost elements of the system are explained below: 

1.  Ensure  and  maintain  integration  with  existing  driving  licence  issuance  system.  This 
element provides the estimated costs of integrating the existing driving licence issuing system 
with the module that generate the digital driving licence (see point 4 below). 

2.  Build/implement and maintain validator app. This element provides the estimated costs of 
developing  and maintaining a validator app that  can be used by  authorities to  validate the 
digital driving licence presented to them as a QR code. 

3.  Build and maintain API for licence registry. This element provides the estimated costs of 
implementing an API (Application Programming Interface) in the existing licence registries 
that  can  be  used  by  the  validator  app  to  query  additional  details  or  obtain  up-to-date 
information about the status of the licence presented. 

4.  Build and maintain the generator for digital driving licence. This element provides the 
estimated  costs  of  implementing  and  maintaining  the  module  that  can  generate  the  digital 
secure document that will be held in the EU Digital Identity Wallet. This include generating 
the secure QR code. 

5.  Build DDL secure document (based on the EU Wallet). This element provides the cost of 
establishing the secure document data structure based on the EU Digital Identity Wallet and 
maintaining this. 

In the assessment of costs, the following assumptions have been made: 

107 

 
 
1.  The European Digital Identity Wallet is available (i.e. part of the baseline) so that Member 

States do not need to implement the app that holds the digital licence. 

2.  The annual maintenance costs are assumed to be 15% of the investments costs.  

The number of hours per element, required for building the system for Member States that do not 
have such system in place is estimated as follows: 

1.  Ensure and maintain integration with existing driving licence issuance system  

Investment costs (one-off in 2025): 
Maintenance costs (annual recurring costs from 2026): 

4,500 hours 
675 hours 

2.  Build/implement and maintain validator app  

Investment costs (one-off in 2025): 
Maintenance costs (annual recurring costs from 2026): 

3,500 hours 
525 hours 

3.  Build and maintain API for licence registry  

Investment costs (one-off in 2025): 
Maintenance costs (annual recurring costs from 2026): 
4.  Build and maintain generator for digital driving licence 
5.  Investment costs (one-off in 2025): 

Maintenance costs (annual recurring costs from 2026): 
6.  Build DDL secure document (based on EU Wallet) 
7.  Investment costs (one-off in 2025): 

Maintenance costs (annual recurring costs from 2026): 

8.  Contingency costs (buffer) 
9.  Investment costs (one-off in 2025): 

Maintenance costs (annual recurring costs from 2026): 

4,500 hours 
675 hours 

3,500 hours 
525 hours 

3,000 hours 
450 

3,500 hours 
525 hours 

Thereby, for Member States that do not have any system in place the total number of hours required 
for  implementing  the  system  in  2025  is  estimated  at  22,500  hours,  while  3,375  hours  would  be 
required annually from 2026 onwards for maintenance. Differences in infrastructure costs driven by 
the need to support more users are expected to be negligible. The evidence for the implementation 
costs  is  based  on  the  experience  of  Denmark  and  Norway.  Both  these  countries  include  the 
implementation of a wallet, which will be built within the EU Digital Identity Wallet.  

For Member States that already have a system in place or indicated plans to implement a system in 
the  coming  years  (AT,  BE,  DE,  DK,  EL,  ES,  FI,  IT,  IE,  NL,  PL),  reflected  in  the  baseline,  the 
additional number of hours for the implementation is estimated at 11,000. This assumes that some 
activities would still be required (for example to ensure compliance with ISO18013-5 and connection 
to the EU Wallet), but these costs are expected to be lower relative to MS with no system in place. 
The number of hours required for maintenance would be however the same, estimated at 3,375 hours 
per year.  

To estimate the costs, the tariffs per hour from  the Eurostat  Structure of  earnings survey,  Labour 
Force Survey data for Non-Wage Labour Costs (i.e. ISCO 2 – professionals) have been used.  

The IT system would involve one-off costs of EUR 12.9 million in 2025 plus annual maintenance 
costs estimated at EUR 1.9 million from 2026 onwards, relative to the baseline. Expressed as present 
value over the 2025-2050 period, the adjustment costs for the Member States authorities are estimated 
at EUR 46.7 million relative to the baseline (in 2021 prices), of which EUR 12.9 million one-off costs 
in 2025.  

108 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
The estimated one-off and recurrent maintenance costs by Member State are provided in Table 19. 

Table 19: Estimated one-off and recurrent maintenance costs (in EUR) by Member State for implementing the IT 
system for mobile driving licences in PMc9, relative to the baseline  

One-off costs in 2025 (EUR) 

Recurrent costs from 2026 (EUR) 

Austria 
Belgium 
Bulgaria 
Cyprus 
Croatia 
Czech Republic 
Denmark 
Estonia 
Finland 
France 
Germany 
Greece 
Hungary 
Ireland 
Italy 
Latvia 
Lithuania 
Luxembourg 
Malta 
Netherlands 
Poland 
Portugal 
Romania 
Slovenia 
Slovakia 
Spain 
Sweden 
EU27 
Source: COWI, Ecorys and NTUA (2022), Impact assessment support study 

490,574 
582,136 
173,967 
589,338 
317,249 
420,512 
569,391 
403,933 
467,516 
1,030,330 
540,619 
238,736 
307,649 
543,562 
477,643 
324,963 
287,302 
1,088,898 
470,699 
490,449 
161,627 
472,417 
321,794 
454,282 
346,205 
336,715 
1,019,310 
12,927,816 

Enforcement costs savings for Member States administrations 

73,586 
87,320 
26,095 
88,401 
47,587 
63,077 
85,409 
60,590 
70,127 
154,550 
81,093 
35,810 
46,147 
81,534 
71,647 
48,744 
43,095 
163,335 
70,605 
73,567 
24,244 
70,863 
48,269 
68,142 
51,931 
50,507 
152,897 
1,939,172 

The introduction of the EU mobile driving licences (PMc9) is expected to lead to costs savings with 
the production of driving licences as the physical licence card is no longer the default option for the 
issuance of licences. 

Currently, the Directive requires a physical driving licence for mutual  recognition within the EU. 
Since  the  administrative  validity  of  a  licence  is  usually  between  10  to  15  years,  in  the  baseline 
scenario it is projected that all road users would still have a physical licence card, as they are expected 
to cross the border at least once in 10 to 15 years.  

The evidence for the production costs of driving licences draws on data for BE, DK and NL. The 
production cost per driving licence is estimated at EUR 5.8 in BE, EUR 9.3 in DK and EUR 9.7 in 
NL.  Expressed  as  share  of  the  licence  cost  (the  fee  that  the  driver  needs  to  pay  to  the  issuing 
authority), this is estimated at 29% for BE, 21% for DK and 24% for NL. On average, the production 
costs in these countries accounts for 25% of the total costs.  

109 

 
  
In PMc9 it is assumed that the cost of renewing, issuing and exchanging a licence is reduced by 25% 
relative to the baseline. However, there would likely still be licence holders that would like to have 
a physical licence, for example because they are digitally illiterate. Based on data from Eurostat232, 
about 20% of people in the EU do not have the required digital skills. Thereby, it is assumed that 
about one-fifth of licence holders would still require a physical driving licence in PMc9. In addition, 
drivers sometimes also use their licence in a Third Country that does not recognise a digital driving 
licence. The assessment is focused on the share of drivers that might use their licence in Africa, Asia 
or South America. For other regions, it has been assumed that they will adopt a driving licence system 
that  would  recognise  the  EU  mobile  driving  licence.  The  share  of  trips  to  Africa,  Asia  or  South 
America is estimated at 2.8% of all trips of EU citizens. These licence holders are assumed to still 
require a physical licence to be able to drive in one of the above mentioned regions. Both the digital 
literacy levels and the share of trips to Africa, Asia or South America are differentiated by Member 
State in the estimation of the costs savings.  

Thus, the introduction of the EU mobile driving licences (PMc9) is expected to lead to enforcement 
costs savings for Member States administrations, for the production of driving licences, estimated at 
EUR  129  million  in  2030  and  EUR  145.5  million  in  2050  relative  to  the  baseline.  Expressed  as 
present  value  over  the  2025-2050  period,  the  costs  savings  are  estimated  at  EUR  2,312  million 
relative to the baseline (in 2021 prices). 

The estimated enforcement costs savings for Member States administrations, by Member State, are 
provided in Table 20. 

Table  20:  Enforcement  costs  savings  for  Member  States  administrations  in  PMc9,  relative  to  the  baseline  (in 
million) 

2030 

2050 

Austria 
Belgium 
Bulgaria 
Cyprus 
Croatia 
Czech Republic 
Denmark 
Estonia 
Finland 
France 
Germany 
Greece 
Hungary 
Ireland 
Italy 
Latvia 
Lithuania 
Luxembourg 
Malta 
Netherlands 
Poland 
Portugal 
Romania 
Slovenia 

232  ISOC_SK_DSKL_I21  

110 

3.4 
1.3 
0.4 
0.3 
0.6 
0.4 
2.1 
0.5 
2.3 
12.2 
19.7 
8.0 
0.3 
3.5 
13.6 
0.2 
0.4 
0.1 
0.3 
3.8 
28.6 
1.7 
1.4 
0.3 

3.8 
1.5 
0.5 
0.3 
0.7 
0.5 
2.2 
0.6 
2.4 
13.0 
23.8 
9.2 
0.4 
4.0 
14.6 
0.2 
0.5 
0.2 
0.4 
4.0 
32.5 
1.9 
1.8 
0.3 

 
 
                                                 
2030 

2050 

Slovakia 
Spain 
Sweden 
EU27 
Source: COWI, Ecorys and NTUA (2022), Impact assessment support study 

0.7 
20.7 
2.2 
129.0 

Administrative costs savings for Member States administrations 

0.8 
23.0 
2.6 
145.5 

The introduction of the EU driving licence (PMc9) is also expected to lead to administrative costs 
savings for Member States administrations. These costs are related to the time spent to ensure that 
the physical licences are issued to the right person, and thus the time spent to validate the identity of 
the person to which a new licence is provided. When procedures are digitised, the time spent on such 
procedures and the associated costs are overcome. 

A study by the World Bank233 on the Estonian e-Government system conservatively estimated that 
each request could save some 15 minutes compared to the case where the system was not in place. 
Drawing on the World  Bank paper it is  conservatively  assumed that 15  minutes are saved for  all 
procedures related to the application or renewal of a driving licence. To estimate the cost savings, the 
tariffs  per  hour  from  the  Eurostat  Structure  of  earnings  survey,  Labour  Force  Survey  data  for 
Non-Wage Labour Costs (ISCO 5) have been used.  

The administrative costs savings for Member States administrations are thus estimated at EUR 90.8 
million in 2030 and EUR 133.2 million in 2050 relative to the baseline. Expressed as present value 
over the 2025-2050 horizon (in 2021 prices), the total administrative costs savings for the Member 
States administrations are estimated at EUR 1,969.3 million in PMc9 in all policy options. 

Hassle costs savings for road transport operators  

PMc9 is  estimated to  lead to  a reduction in  hassle costs for the renewal  of the category C and D 
licences. Drawing on the World Bank study234, it has been assumed that each renewal request saved 
15 minutes on average compared to the case where the system was not in place. The C and D licences 
are mainly used by professional drivers and the costs savings are thus expected to benefit transport 
operators, mainly SMEs in the road transport sector (i.e. 99% of the road transport operators)235. The 
hassle  costs  savings  are  derived  by  using  the  average  labour  costs  by  Member  State236,  and  are 
estimated  at  EUR  32.8  million  in  2030  and  EUR  38.7  million  in  2050  relative  to  the  baseline. 
Expressed as present value over the 2025-2050 horizon (in 2021 prices), total hassle costs savings 
for road transport operators are estimated at EUR 587 million in PMc9. 

Hassle costs savings for citizens  

PMc9 is  estimated to  lead to  a reduction in  hassle costs for the renewal  of the category A  and B 
licences. Drawing on the Worldbank study237, it has been assumed that each renewal request saved 
15 minutes on average compared to the case where the system was not in place. The hassle costs 
savings for citizens are estimated at EUR 72.7 million in 2030 and EUR 116 million in 2050 relative 

233  https://thedocs.worldbank.org/en/doc/165711456838073531-0050022016/original/WDR16BPEstonianeGovecosystemVassil.pdf  
234  https://thedocs.worldbank.org/en/doc/165711456838073531-0050022016/original/WDR16BPEstonianeGovecosystemVassil.pdf  
235  https://eur-lex.europa.eu/resource.html?uri=cellar:9d5c61bf-4629-11e7-aea8-01aa75ed71a1.0001.02/DOC_1&format=PDF  
236  Eurostat Structure of earnings survey, Labour Force Survey data for Non-Wage Labour Costs 
237  https://thedocs.worldbank.org/en/doc/165711456838073531-0050022016/original/WDR16BPEstonianeGovecosystemVassil.pdf  

111 

 
 
                                                 
to the baseline. Expressed as present value over the 2025-2050 horizon (in 2021 prices), total hassle 
costs savings for citizens are estimated at EUR 1,697.2 million in PMc9. 

The costs and costs savings of PMc9 are the same in all policy options. 

PMc10: Introduction of a possible QR code on the physical licence in the areas reserved for 
microchip 

Enforcement costs savings for Member States administrations 

In PMc10 it would be possible to print a QR code in the space reserved on physical driving licences 
for  microchips.  It  would  provide  access  to  additional  information,  not  displayed  on  the  physical 
driving licence. 

PMc10 would lead to a reduction in the production cost of licences. The difference in costs between 
a licence with  a microchip  and a licence with  a digitally signed bar code is  estimated to be EUR 
0.50238. In both cases the same information would be stored, but it would either be stored on a digitally 
signed  QR  code  or  on  a  microchip.  In  the  baseline  scenario,  only  Netherlands  makes  use  of  the 
microchip and it is thus the only country affected by the measure. 

The enforcement costs savings due to the introduction of a QR code on the physical licence in the 
areas reserved for microchip (PMc10) are estimated to be limited (EUR 0.03 million in 2030 and 
0.04 million  in  2050) relative to  the baseline. This  is  because only the  Netherlands makes use of 
microchips and also because most driving licences would become digital in all policy options, as an 
effect  of  PMc9.  Expressed  as  present  value  over  the  2025-2050  horizon  (in  2021  prices),  the 
enforcement costs savings for Member States administrations are estimated at EUR 0.6 million in 
PMc10 in all policy options. 

PMc11: Improvement and simplification of rules on administrative validity  

Enforcement costs savings for Member States administrations 

In PMc11, the 15 years long administrative validity of driving licences for A and B categories will 
be made mandatory and exclusive.  

The Directive currently requires an administrative validity period of 10 years, but allows Member 
States to also issue licence for 15 years. For Member States that are already issuing licences for 15 
years by default (AT, CY, CZ, DE, FI, FR, EL, LU, PL, PT, SK and DK) the measure would have 
no impact.  

For all other Member States, the number of licences that would have to be renewed is estimated to 
decrease  by  1.8  million  in  2030  and  3.7  million  in  2050.  PMc11  is  thus  estimated  to  lead  to 
enforcement costs savings of EUR 16.9 million in 2030 and EUR 35.7 million in 2050 relative to the 
baseline, due to the lower number of licences to be renewed. Expressed as present value over the 
2025-2050 horizon (in 2021 prices), the enforcement costs savings for Member States administrations 
are estimated at EUR 518.3 million in PMc11 in all policy options. 

The estimated enforcement costs savings for Member States administrations, by Member State, are 
provided in Table 21. 

238  https://internetpkg.com/average-cost-of-manufacturing-a-sim-card/  

112 

 
                                                 
Table 21: Enforcement costs savings for  Member States administrations in PMc11, relative to the baseline (in 
million) 

2030 

2050 

Austria 
Belgium 
Bulgaria 
Cyprus 
Croatia 
Czech Republic 
Denmark 
Estonia 
Finland 
France 
Germany 
Greece 
Hungary 
Ireland 
Italy 
Latvia 
Lithuania 
Luxembourg 
Malta 
Netherlands 
Poland 
Portugal 
Romania 
Slovenia 
Slovakia 
Spain 
Sweden 
EU27 
Source: COWI, Ecorys and NTUA (2022), Impact assessment support study 

- 
0.8 
0.3 
- 
0.3 
- 
- 
0.1 
- 
- 
- 
- 
0.3 
0.6 
6.5 
0.1 
0.1 
- 
0.1 
2.3 
- 
- 
0.9 
0.1 
- 
3.3 
0.9 
16.9 

- 
1.7 
0.6 
- 
0.5 
- 
- 
0.2 
- 
- 
- 
- 
0.6 
1.6 
13.5 
0.2 
0.1 
- 
0.4 
5.1 
- 
- 
1.6 
0.2 
- 
7.2 
2.2 
35.7 

PMc12: Mutual recognition of optional equivalences – New equivalence applicable to small bus 
combined with a trailer  

Administrative costs savings for road transport operators  

In  PMc12  the  optional  equivalence  would  be  mutually  recognised.  For  that  purpose,  an  EU  code 
would  be  introduced  for  each  of  the  optional  equivalence  of  the  Directive.  A  licence  granted  for 
categories D1 and CE shall be valid to drive vehicles in category D1E. 

In the baseline scenario, a new driving test is required to allow a driver with a D1 licence to obtain a 
D1E licence. In PMc12, if a drivers already has a D1 and a CE licence, the drivers does not have to 
pass  another  exam.  The  C  and  D  licences  are  mainly  used  by  professional  drivers  and  the  costs 
savings are thus expected to benefit transport operators, mainly SMEs in the road transport sector. 
However,  the  number  of  D1  licence  holders  is  negligible  at  the  EU  level  (e.g.  in  Germany,  D1 
category licences represent only 0.002% of all licences) and the share of holders of a D1 and a CE 
licence  is  even  lower.  Therefore,  the  administrative  costs  savings  due  to  the  measure  would  not 
expected  to  be  significant  and  are  not  estimated.  The  measure  would  however  benefit  some  road 
transport operators.  

PM1: Rules on training and probation periods - Recommendation on lifelong training 

113 

 
 
PM1 foresees rules on accompanied driving for drivers who are between 17 and 18 years old after 
passing the driving test will be introduced for categories B and C. It will include a specific EU code 
and standards applicable to accompaniers. It will require to reduce for this specific case the minimum 
age from 18 to 17 years old to be professionally qualified (Directive (EU) 2022/2561). A probation 
period of a minimum of 2 years will be established for novice drivers. It will be subject to strict rules 
related to driving under influence (zero tolerance) and potentially additional rules and/or restrictions 
defined by each MS. A recommendation will be adopted for lifelong training, with the objective to 
maintain drivers’ skills  and knowledge on advanced technologies. PM1  is  not  expected to  have a 
significant impact on costs.  

PM2: Amendments to the definition of the mopeds’ category to include certain micro mobility 
means 

In PM2 the category AM will include all vehicles with a speed between a maximum speed of 25 and 
45 km/h, including micro-mobility means. It will not cover vehicles with a maximum speed below 
25 km/h. PM2 is not expected to have a significant impact on costs. 

PM3: Introduction of a new category for tractors - amendment to the definition of the small 
bus category  

In PM3 the mutual recognition of national licences for tractors will be introduced. In addition, the 
number of maximum passengers for vehicles of category D1 will be increased from 16 to 22. 

The  introduction  of  tractor  licences  has  two  counteracting  effects.  On  the  one  hand,  the  mutual 
recognition of licences for agricultural vehicles is expected to facilitate the work of seasonal workers 
and farmers in the border areas. On the other hand, the introduction of the T-EU licence would imply 
that applicants would need to undergo mandatory training and testing, which may not be currently 
required by Member States. Hence, this might increase the costs of obtaining a T-licence relative to 
the baseline. It was not possible to estimate the costs and benefits associated to PM3 but their size is 
expected to be small.  

The revised definition for the number of passengers to be carried under a D1 licence is expected to 
have a positive impact on road transport operators, as they will be able to carry more passengers. The 
share of D1 licences is however low (e.g. only 0.002% in Germany) and the impact on costs savings 
is thus expected to be limited. However, the measure may particularly benefit SMEs that provide 
services in remote areas.  

PM4: Mutual recognition of driving disqualifications 

Enforcement costs for Member States administrations 

In PM4 driving disqualifications resulting from specific offenses (speed driving and driving under 
the influence of alcohol) would be mutually recognised. PM4 would lead to enforcement costs for 
Member States administrations relative to the baseline, to ensure that driving disqualifications can be 
imposed on foreign drivers (e.g. drivers that have a licence which was not issued by the Member 
State in which the offence was committed). The associated costs are related to the additional time 
spent on investigations and the costs associated to the notification of the foreign offender. 

In  order  to  calculate  the  costs  associated  to  PM4,  first  an  estimation  of  the  increase  in  driving 
disqualifications for (severe) speeding offences and offences associated to driving under the influence 
of alcohol relative to the baseline is needed.  

114 

 
The total number of offences committed by drivers in foreign registered vehicles is aligned with those 
used in the impact assessment supporting the revision of the CBE Directive as there should be no 
difference between the numbers of detected speeding and drink driving offences as regards whether 
they are detected for the purposes of the CBE Directive (i.e. to issue financial penalties) or to pursue 
the  cases  and  issue  driving  disqualification.  In  the  case  of  the  impact  assessment  supporting  the 
revision  of  the  CBE  Directive  however,  the  relevant  number  of  offences  are  the  ones  that  are 
connected to remote detection. For the purpose of this impact assessment, all the offences which are 
detected  are  relevant,  regardless  of  the  method  of  detection,  as  long  as  they  reach  a  level  of 
seriousness that leads to a driving disqualification under the law of the Member State that detected 
he offence. 

Speeding  offences.  The  number  of  speeding  offences  is  available  for  20  Member  States.  For  the 
remaining Member States the number of speeding offences has been extrapolated drawing on the 
number of speed cameras in each Member State. The number of offences committed abroad is projected 
to decrease by 2040 (from 91.7 million in 2019 to 86.9 million in 2040) due to the gradual introduction 
of new safety features in the vehicle fleet, due to the General Safety Regulation239. However, as the effect 
of the introduction of new safety features in the vehicle fleet is expected to peter out by 2040, the number 
of detected offences is projected to increase again post-2040 (to 92.2 million by 2050). Around 15% of 
all  traffic  offences  are  estimated  to  be  committed  by  drivers  in  foreign  registered  vehicles240.  In 
addition, drawing on data for Belgium, the share of severe speeding offences that might result in a 
driving  disqualification  has  been  estimated  at  0.9%.  The  number  of  driving  disqualifications  for 
severe speeding offences is thus estimated at 117,643 in 2030 and 123,639 in 2050 relative to the 
baseline.  

Driving under the influence of alcohol (DUI) offences. The number of DUI offences is available for 
15  Member  States.  In  order  to  estimate  the  DUI  offences  for  the  remaining  MS,  the  historical 
information on the percentage of drivers that were tested positively during checks has been used241. 
The number of DUI offences is estimated at 1.2 million in 2019 and it is projected to increase to 1.5 
million by 2030 and 2.4 million by 2050, drawing on the development of enforcement intensity over 
the  period  2010-2019242.  Findings  from  the  DRUID  project  were  used  to  estimate  the  share  of 
offences in which the tested blood alcohol concentration (BAC) was higher than 0.8 g/l243. On the 
EU level, some 26% of all alcohol offences were estimated to be severe, risking losing the licence. 
In addition, as for the speed offences it has been assumed that around 15% of all traffic offences are 
committed by drivers in foreign registered vehicles244. The number of driving disqualifications for 
driving under the influence of alcohol is thus estimated at 64,871 in 2030 and 101,361 in 2050 relative 
to the baseline. 

The total number of driving disqualifications for (severe) speeding offences and for driving under the 
influence of alcohol is estimated at 182,514 in 2030 and 225,000 in 2050 relative to the baseline.  

239  Regulation (EU) 2019/2144, OJ L 325, 16.12.2019, p. 1. 
240  Ecorys  et  al.  (2022),  Impact  Assessment  support  study  for  the  revision  of  Directive  (EU)  2015/413  facilitating  cross-border 

exchange of information on road-safety-related traffic offences 

241  Ecorys,  Instytut  Transportu  Samochodowego  (ITS)  (2022):  Prevention  of  driving  under  the  influence  of  alcohol  and  drugs  - 

Publications Office of the EU (europa.eu) 

242  ibid 
243  European Monitoring Centre for Drugs and Drug Addiction (2012): Driving Under the Influence of Drugs, Alcohol and Medicines 

in Europe – findings from the DRUID project (TDXA12006ENN_402402.pdf (europa.eu)) 

244  Ecorys  et  al.  (2022),  Impact  Assessment  support  study  for  the  revision  of  Directive  (EU)  2015/413  facilitating  cross-border 

exchange of information on road-safety-related traffic offences 

115 

 
                                                 
Investigation costs. Based on stakeholders’ consultation in the context of the impact assessment for 
the revision of the CBE Directive, the investigation time per foreign registered offence is currently 
around 15 minutes. The time spent on investigation depends to a large extent on whether the process 
is  automated  or  not.  Member  States  that  adopt  an  automated  system,  and  adopt  an  owner/holder 
liability  regime,  generally  have  an  investigation  time  between  1  and  3  minutes.  In  the  baseline 
scenario, a decrease in the investigation time of 5% per year has been assumed. The investigation 
time is thereby estimated at 15 minutes in 2019, 8.5 minutes in 2030, 5.1 minutes in 2040 and 3.1 
minutes in 2050245.  

Mailing  costs  for  successfully  investigated  offences.  The  postal  charges  for  sending  regular  mail 
within EU are estimated to be between 1 and 2 EUR, and the postal charges for registered mail are 
estimated at 4 to 5 EUR246,247,248,249,250. Based on desk research in the context of the impact assessment 
support study for the revision of the CBE Directive, it was found that Germany251, the Netherlands252, 
Belgium253 and France254 generally use ‘standard’ mail for sending penalty notices, and that Italy255 
and Spain256 require the information letter to be sent via registered mail257. In the baseline scenario, 
it has thus been assumed that 50% of the letters are sent via registered mail and 50% via standard 
mail. Thus, the mailing cost per penalty notice sent abroad within EU was estimated at 3 EUR. 

Total enforcement costs for Member States authorities related to driving disqualifications for (severe) 
speeding offences and for driving under the influence of alcohol are estimated at EUR 1.5 million in 
2030  and  EUR  1.1  million  in  2050  relative  to  the  baseline.  Expressed  as  present  value  over  the 
2025-2050 horizon (in 2021 prices), the enforcement costs for Member States administrations are 
estimated at EUR 26.3 million in PM4. PM4 is only included in PO-B. 

The estimated enforcement costs for Member States administrations, by Member State, are provided 
in Table 22. 

Table 22: Enforcement costs for Member States administrations in PM4, relative to the baseline (in thousand) 

2030 

2050 

Austria 
Belgium 
Bulgaria 
Cyprus 
Croatia 
Czech Republic 
Denmark 

51.1 
88.5 
5.4 
4.8 
16.7 
26.3 
2.0 

31.0 
54.6 
6.3 
3.7 
17.0 
22.4 
1.5 

245  Ecorys  et  al.  (2022),  Impact  Assessment  support  study  for  the  revision  of  Directive  (EU)  2015/413  facilitating  cross-border 

exchange of information on road-safety-related traffic offences 

246  https://www.deutschepost.de/de/p/portoberater.html#/Brief/International/Rechteckig/bis_235_x_125_mm/bis_20_g/Guenstig  
247  https://www.postnl.nl/versturen/brief-of-kaart-versturen/brief-of-kaart-buitenland/  
248  https://www.bpost.be/nl/tarieven  
249  https://www.poste.it/gamma/lettera.html  
250  https://cennik-poczta--polska-

pl.translate.goog/usluga,zagraniczny_przesylka_listowa.html?_x_tr_sl=pl&_x_tr_tl=en&_x_tr_hl=nl&_x_tr_pto=ajax,se,elem  

251  https://www.bussgeldkatalog.org/bussgeldbescheid/per-einschreiben/  
252  https://wetten.overheid.nl/BWBR0004581/2021-01-01  
253  https://www.verkeerszaken.be/artikel/a/97/Wat-u-moet-weten-over-www-verkeersboeten-be  
254  https://www.comparateur-stagespermis.com/infractions-et-amendes  
255  https://quifinanza.it/info-utili/notifica-multa-quando-avviene/316997/  
256  https://motor.elpais.com/conducir/no-sabes-si-te-han-puesto-una-multa-aqui-puedes-enterarte/  
257  It should be noted that some Member States, such as Belgium and France, do sent letters via registered mail if no payment is made 

after the first letter has been sent via ordinary mail. 

116 

 
 
 
                                                 
2030 

2050 

Estonia 
Finland 
France 
Germany 
Greece 
Hungary 
Ireland 
Italy 
Latvia 
Lithuania 
Luxembourg 
Malta 
Netherlands 
Poland 
Portugal 
Romania 
Slovenia 
Slovakia 
Spain 
Sweden 
EU27 
Source: COWI, Ecorys and NTUA (2022), Impact assessment support study 

3.5 
52.2 
191.0 
253.9 
18.4 
12.3 
0.4 
564.8 
3.5 
10.6 
1.9 
0.9 
30.8 
25.5 
5.7 
9.0 
4.5 
1.3 
72.2 
92.1 
1,549.3 

3.3 
35.2 
137.9 
173.9 
16.3 
12.6 
0.3 
403.8 
3.2 
10.3 
1.3 
0.8 
22.8 
24.5 
5.1 
9.9 
4.0 
1.3 
54.2 
57.4 
1,114.7 

PM5: Rules on consequences of penalty points for non-residents - Rules on rehabilitation in 
case of a change of normal residence 

Enforcement costs for Member States administrations 

In PM5, penalty points will be also applied to non-residents and driving disqualification resulting 
from penalty points system should be mutually recognised. PM5 would lead to enforcement costs for 
Member States administrations relative to the baseline, to ensure that penalty points are also applied 
on foreign drivers. The associated costs are related to the additional time spent on investigations and 
the costs associated to the notification of the foreign offender. 

In order to calculate the costs associated to PM5, first an estimation of the increase in the number of 
cases where the penalty points need to be applied for (severe) speeding offences and for driving under 
the influence of alcohol relative to the baseline is needed. 

The estimation follows a similar approach as for PM4. However, for driving under the influence of 
alcohol, the number of awarded penalty points is estimated by considering cases with a blood alcohol 
concentration above 0.5 (instead of 0.8 in PM4). As a result, 107,237 additional cases are estimated 
for 2030 and 167,558 for 2050 relative to the baseline. For speeding, a similar approach was used as 
for PM4, but drawing on data for Belgium the share of severe speeding offences that might result in 
penalty points has been estimated at 3.2%. As a result, the number of cases in which penalty points 
would be awarded has been estimated at 418,050 in 2030 and 439,357 in 2050 relative to the baseline. 

The total number of cases where the penalty points need to be applied for (severe) speeding offences 
and for driving under the influence of alcohol is estimated at 525,288 in 2030 and 606,915 in 2050 
relative to the baseline.  

The same assumptions for the investigation costs and mailing costs per case have been used as in 
PM4.  Total  enforcement costs for Member States authorities are estimated at  EUR  4.5 million  in 

117 

 
 
2030  and  EUR  3  million  in  2050  relative  to  the  baseline.  Expressed  as  present  value  over  the 
2025-2050 horizon (in 2021 prices), the enforcement costs for Member States administrations are 
estimated at EUR 75.3 million in PM5. PM5 is only included in PO-C. 

The estimated enforcement costs for Member States administrations, by Member State, are provided 
in Table 23. 

Table 23: Enforcement costs for Member States administrations in PM5, relative to the baseline (in thousand) 

2030 

2050 

Austria 
Belgium 
Bulgaria 
Cyprus 
Croatia 
Czech Republic 
Denmark 
Estonia 
Finland 
France 
Germany 
Greece 
Hungary 
Ireland 
Italy 
Latvia 
Lithuania 
Luxembourg 
Malta 
Netherlands 
Poland 
Portugal 
Romania 
Slovenia 
Slovakia 
Spain 
Sweden 
EU27 
Source: COWI, Ecorys and NTUA (2022), Impact assessment support study 

180.3 
301.9 
11.8 
14.2 
39.4 
79.1 
6.0 
9.1 
162.8 
516.9 
732.8 
47.1 
27.9 
1.1 
1,583.0 
10.5 
27.3 
5.5 
2.6 
81.5 
66.7 
14.2 
18.2 
12.1 
2.6 
229.2 
311.9 
4,495.4 

PM 6: Rules on simple medical screening 

108.8 
183.3 
12.9 
10.4 
37.3 
63.7 
4.2 
7.9 
104.5 
346.8 
470.1 
38.7 
25.9 
0.7 
1,056.1 
8.9 
24.2 
3.6 
2.1 
56.1 
59.1 
11.8 
18.9 
9.9 
2.6 
165.8 
190.3 
3,024.8 

In  PM6  non-binding  guidelines  would  be  established  for  assessing  applicants’  vision  for  group  1 
drivers  (A  and  B  category  licence).  Medical  screening  will  be  mandatory  at  renewal  for  group  1 
drivers, based on a self-assessment triggering assessments by a general practitioner and/or a specialist 
if required. More frequent medical screening will be possible for drivers of the age of 70 years old. 
In addition, an instrument will be established to prepare training material related to medical screening 
for general practitioners (in all EU languages). PM6 is only included in PO-B. 

Adjustment costs for the European Commission  

PM6 would require the development of an (online) training programme for general practitioners. The 
costs for developing the  online content of the training programme are estimated at  EUR 8,500 to 

118 

 
 
36,000 per hour258. Thus, a four hour online training is estimated at EUR 33,500 to EUR 142,000, 
depending on the level of detail. The training programme is assumed to be updated regularly (once 
every five  years), starting from 2025.  Expressed as present  value over the 2025-2050 horizon (in 
2021  prices),  the  adjustment  costs  for  the  European  Commission  are  estimated  at  EUR  0.1  to 
0.6 million. 

Adjustment costs for general practitioners  

The number of general practitioners (GPs) in the EU is estimated at around 460 thousand259 and it is 
projected  to  increase  to  around  484  thousand  by  2030  and  544  thousand  by  2050  in  the  baseline 
scenario, increasing at somewhat lower rates than in the past. To estimate the number of (online) 
training  courses  required,  it  is  assumed  that  each  GP  needs  to  attend  the  training  each  five  year 
starting from 2025 and the class size is of 15 GPs260. PM6 is expected to lead to additional training 
courses for GPs in all MS except for EL, HU, IT, LV, PL, RO and ES that are expected to continue 
to implement a stricter screening (medical assessment instead of screening) and for which a training 
of GPs to support the screening is not required. Thus, PM6 is expected to lead to 4,515 additional 
(online) training courses for general practitioners in 2030 and 5,057 in 2050, relative to the baseline. 
The training is assumed to take four hours and the cost for the trainer is assumed at EUR 150 per 
hour on average at EU level. The adjustment costs for general practitioners in PM6 are estimated at 
EUR 3.1 million in 2030 and EUR 3.4 million in 2050 relative to the baseline. Expressed as present 
value over the 2025-2050 horizon (in 2021 prices), they are estimated at EUR 57.7 million.  

Adjustment costs savings for citizens 

In PM6 more frequent medical screening would be possible for drivers above 70 years old. However, 
this  measures  needs  to  be  assessed  in  combinations  with  PMc11,  where  shorter  administrative 
validity for the driving licences for A and B categories than 15 years would not be allowed for fit 
drivers before 70 years old. The measure only affects the holders of  driving licences for A and B 
categories. 

Data for driving licences by age group are available for DE261, IT262, NL263, LV264, SK265, FI266 and 
SE267. On average, for these Member States 16% of licences for A and B categories are attributed to 
drivers above 70 years old, 21% to drivers above 65 year old, 29% to drivers above 60 years old and 
47% to drivers above 50 years old. To estimate the number of driving licences by age group at EU 
level, the average share by age group has been assumed for MS where data is not available. In the 
following  step,  the  number  of  ‘age-dependent’  medical  tests  that  were  conducted  in  the  period 
2017-2021 was estimated by applying the current rules per Member State to the number of licences 
held by elder people. In the baseline scenario, the number of ‘age-dependent’ medical tests has been 
assumed to grow in line with the population projections from Eurostat for the relevant age group268.  

258  https://raccoongang.com/blog/how-much-does-it-cost-create-online-course/  
259  Source : Eurostat (hlth_rs_sp) 
260  Literature suggests that a class size of 12 to 21 is deemed optimal. 
261  https://www.kba.de/DE/Statistik/Kraftfahrer/Fahrerlaubnisse/Fahrerlaubnisbestand/fahrerlaubnisbestand_node.html  
262  https://www.anfia.it/data/studi-e-statistiche/automobili-cifre/miscellaneous/08italiapatenti.xlsx  
263  https://opendata.cbs.nl/statline/#/CBS/nl/dataset/83488NED/table?ts=1659960260602  
264  https://www.csdd.lv/vaditaja-apliecibas/vaditaja-apliecibas   
265  https://www.minv.sk/?statisticke-prehlady-agendy-vodicov-a-vodicskych-preukazov  
266  https://trafi2.stat.fi/PXWeb/pxweb/fi/TraFi/TraFi__Ajokortit/010_ajok_tau_101.px/  
267  https://www.transportstyrelsen.se/sv/vagtrafik/statistik/Korkort/Statistik-over-korkortsinnehavare-efter-kon/  
268  Source : Eurostat (PROJ_19NP) 

119 

 
                                                 
To estimate the impact of PM6, an assessment was made for Member States that currently use the 
provision of the Directive to reduce the administrative validity of licences for people above 50 years 
old. Thus, the reduction in the number of medical tests has been estimated for lifting the age limit 
from 50 to 70 years old. This yields significant differences by Member State: 

1.  For 6 Member States (AT, BE, DE, PL, RO and SE), no impact is expected as they do not 
make use of the possibility to reduce the administrative validity to increase the frequency of 
medical testing. 

2.  For 6 Member States (CY, EE, FI, IE, NL, SI), no impact is expected as they have chosen an 
age limit that is either at 70 years old (CY, EE, FI, IE, SI) or above (75 year old for NL). 
3.  For 3 Member States (BG, HR and MT), no information is available and the impact has thus 

not been quantified. This implies that they are assumed not to be affected by PM6. 

4.  For the remaining Member States, a reduction in the number of medical tests is expected as 
they currently shorten the administrative validity of driving licences for A and B categories 
below 70 years old (DK, FR, HU, LT and LV to 50 years old; CZ, LU and PT to 65 years old; 
EL, ES, IT and SK to 65 years old).  

For Member States that require a medical fitness check to be conducted every time that the driving 
licences for A and B categories are renewed (EL, ES, HU, IT, LV and PL) the impact is adjusted 
taking  into  account  the  renewal,  to  avoid  overestimating  the  reduction  in  the  number  of 
‘age-dependent’ medical tests. 

The reduction in the number of ‘age-dependent’ medical tests relative to the baseline, by Member 
State, is provided in Table 24. At EU level, the measure is estimated to result in a reduction of the 
medical tests by 3.6 million in 2030 and 3.4 million in 2050 relative to the baseline.  

Table 24: Reduction in the number of ‘age-dependent’ medical tests in PM6, relative to the baseline (in thousand) 

2030 

2050 

Austria 
Belgium 
Bulgaria 
Cyprus 
Croatia 
Czech Republic 
Denmark 
Estonia 
Finland 
France 
Germany 
Greece 
Hungary 
Ireland 
Italy 
Latvia 
Lithuania 
Luxembourg 
Malta 
Netherlands 
Poland 
Portugal 
Romania 
Slovenia 

- 
- 
- 
- 
- 
136 
63 
- 
- 
2,171 
- 
82 
306 
- 
399 
7 
82 
9 
- 
- 
- 
48 
- 
- 

120 

- 
- 
- 
- 
- 
140 
60 
- 
- 
2,102 
- 
74 
267 
- 
370 
6 
53 
10 
- 
- 
- 
37 
- 
- 

 
 
Slovakia 
Spain 
Sweden 
EU27 
Source: COWI, Ecorys and NTUA (2022), Impact assessment support study 

43 
210 
- 
3,556 

48 
195 
- 
3,364 

2030 

2050 

Data  on  costs  for  a  medical  test  is  available  for  23  Member  States.  The  average  cost  for  the  23 
Member States (EUR 47 per test) has been applied to the 4 Member States (BG, CY, MT and PT) for 
which data is missing. However, for BG, CY and MT the measure is not expected to have an impact.  

Thus, the changes in the rules for the consultation of the GP for elderly people (above 70 years old) 
lead to adjustment costs savings estimated at EUR 131 million in 2030 and EUR 124.2 million in 
2050 relative to the baseline for PM6. Expressed as present value over the 2025-2050 period, the 
adjustment costs savings for citizens are estimated at EUR 2,414 million. 

The reduction in costs with ‘age-dependent’ medical tests relative to the baseline, by Member State, 
is provided in Table 25. 

Table 25: Reduction in costs with the ‘age-dependent’ medical tests in PM6, relative to the baseline (in million) 

2030 

2050 

Austria 
Belgium 
Bulgaria 
Cyprus 
Croatia 
Czech Republic 
Denmark 
Estonia 
Finland 
France 
Germany 
Greece 
Hungary 
Ireland 
Italy 
Latvia 
Lithuania 
Luxembourg 
Malta 
Netherlands 
Poland 
Portugal 
Romania 
Slovenia 
Slovakia 
Spain 
Sweden 
EU27 
Source: COWI, Ecorys and NTUA (2022), Impact assessment support study 

- 
- 
- 
- 
- 
2.8 
3.4 
- 
- 
78.2 
- 
1.6 
2.8 
- 
24.0 
0.3 
2.1 
0.5 
- 
- 
- 
2.3 
- 
- 
0.7 
12.6 
- 
131.0 

Adjustment costs for citizens 

121 

- 
- 
- 
- 
- 
2.9 
3.2 
- 
- 
75.7 
- 
1.5 
2.4 
- 
22.2 
0.2 
1.3 
0.5 
- 
- 
- 
1.8 
- 
- 
0.8 
11.7 
- 
124.2 

 
 
 
PM6  includes  the  screening  of  fitness  to  drive  for  each  driver  renewing  its  driving  licence, 
independent of age and a vision test for applicants.  

For the screening of fitness to drive for each driver renewing their driving licence independent of 
age, several MS (AT, BE, CY, FI,  IE, NL, PT and SE) already apply the measure and thus PM6 
would not have an impact on them relative to the baseline. Other MS (EL, ES, HU, IT, LV, PL, RO) 
require a medical test at the renewal of their driving licence and thus PM6 would not have an impact 
on them. For the remaining MS (BG, CZ, DE, DK, EE, FR, HR, LU, LT, MT, SI, SK), the estimated 
number of renewed licences per year is used to estimate the number of self-assessments. In addition, 
it is assumed that some 8% of all self-assessments would result in  a medical test, drawing on the 
practices regarding periodic screening for the UK269. The increase in the number of medical tests is 
estimated at 0.2 million in 2030 and 0.5 million in 2050 relative to the baseline. Making use of the 
average cost per medical  test by MS, the adjustment costs for citizens are estimated at EUR  18.1 
million in 2030 and EUR 37.6 million in 2050 relative to the baseline. Expressed as present value 
over the 2025-2050 period, they are estimated at EUR 552.9 million relative to the baseline (in 2021 
prices). 

For the vision test, only CY, FR and NL currently use a ‘licence-plate self-test’, while the other MS 
require a vision test. For the ‘licence-plate self-test’, applicants for a driving licence are asked prior 
to their practical exam to read the licence plate of a vehicle that is at some 15 to 20 meters distance. 
As non-binding rules will be established for assessing applicants’ vision in PM6, it has been assumed 
that only CY and NL implement the measure. The additional number of tests relative to the baseline 
are estimated at 404,787 in 2030 (22,782 for CY and 382,004 for NL) and 418,209 in 2050 (24,117 
for CY and 394,032 for NL). Assuming a cost per vision test of EUR 15 to 75 in NL270 and EUR 9 
to 46 EUR in CY, the adjustment costs for citizens are estimated at EUR 5.9 to 29.7 million in 2030 
and EUR 6.1 to 30.7 million in 2050 relative to the baseline. Expressed as present value over the 
2025-2050 period, they are estimated at EUR 110.7 to 553.7 million relative to the baseline (in 2021 
prices). 

The total adjustment costs for citizens for the screening of fitness to drive for each driver renewing 
their driving licence independent of age and for the vision test are estimated at EUR 24 to 47.8 million 
in 2030 and EUR 43.8 to 68.3 million in 2050. Expressed as present value over the 2025-2050 period, 
they are estimated at EUR 663.6 to 1,106.6 million relative to the baseline (in 2021 prices). 

PM7: Rules on advanced medical screening 

In PM7 the applicants’ vision will be checked by certified professionals for group 1 (A and B category 
licence)  drivers.  Medical  screening  will  be  mandatory  at  renewal  for  group  1  drivers,  based  on  a 
self-assessment  filled  out  with  a  general  practitioner  triggering  specific  assessments  if  required. 
Administrative validity of driving licences of group 1 will be shorten to 5 years for drivers of the age 
of 65 years old or above to enable more frequent medical screening. An instrument will be established 
to  prepare  training  material  related  to  medical  screening  for  general  practitioners  (in  all  EU 
languages). PM7 is only included in PO-C. 

Adjustment costs for the European Commission  

269  Source:  https://www.nhs.uk/conditions/nhs-health-check/what-is-an-nhs-health-check-new/;  In  the  UK,  the  assessment  is 
performed by a professional. Under PM6, a self-assessment is assumed  without the involvement of a GP. For this reason it is 
assumed that the procedure is less effective and thus some people that might be medically unfit would not be identified. Therefore, 
the figure for UK (16.1%) is scaled down by 50% to account for this. 

270  https://kostentracker.nl/oogtest-kosten-prijsvoorbeelden-en-meer  

122 

 
                                                 
In PM7 the adjustments costs for the European Commission are the same as those in PM6. Expressed 
as present value over the 2025-2050 horizon (in 2021 prices), they are estimated at EUR 0.1 to 0.6 
million. 

Adjustment costs for general practitioners  

In  PM7  the  adjustments  costs  for  the  general  practitioners  are  the  same  as  those  in  PM6.  The 
adjustment costs are estimated at EUR 3.1 million in 2030 and EUR 3.4 million in 2050 relative to 
the  baseline.  Expressed  as  present  value  over  the  2025-2050  horizon  (in  2021  prices),  they  are 
estimated at EUR 57.7 million. 

Adjustment costs for citizens 

In PM7 the administrative validity of driving licences of group 1 will be shorten to 5 years for drivers 
of the age of 65 years old or above to enable more frequent medical screening. 

The assessment follows the same logic as that for PM6. However in this case all Member States are 
required to test all group 1 drivers above 65 years old every 5 years. As for PM6 this yields significant 
differences by Member State: 

1.  For the 5 Member States (AT, BE, DE, PL, RO and SE) that do not make use of the possibility 
to reduce the administrative validity to increase the frequency of medical testing, PM7 would 
lead to an increase of testing for drivers above 65 years old.  

2.  For the 6 Member States (CY, EE, FI, IE, NL, SI), that have chosen an age limit above 70 
years old, PM7 would also lead to an increase in testing for drivers above 65 years old. 
3.  For 3 Member States (BG, HR and MT), no information is available and the impact has thus 

not been quantified. This implies that they are assumed not to be affected by PM7. 

4.  For the 4 Member States (EL, ES, IT and SK) that have chosen an age limit above 65 years 

old, PM7 is expected to have no impact relative to the baseline. 

5.  For  the  remaining  9  Member  States,  a  reduction  in  the  number  of  medical  tests  would  be 
expected as they currently shorten the administrative validity of driving licences for A and B 
categories below 65 years old (DK, FR, HU, LT and LV to 50 years old; CZ, LU and PT to 
60 years old). However, in the baseline in DK medical tests are conducted  every 15  years 
from the age of 50. In PM7 the frequency is increased to 5 years above 65 years old. For this 
reason, PM7 also leads to an increase in the number of medical tests in DK relative to the 
baseline. Similarly, for PT medical tests are conducted every 15 years from the age of 60. 
PM7  would  thus  lead  to  an  increase  in  the  number  of  medical  tests  in  PT  relative  to  the 
baseline.  

The change in the number of ‘age-dependent’ medical tests relative to the baseline, by Member State, 
is provided in Table 26. At EU level, the measure is estimated to result in an increase in the number 
of medical tests by 2.6 million in 2030 and 3.2 million in 2050 relative to the baseline.  

Table 26: Change in the number of ‘age-dependent’ medical tests in PM7, relative to the baseline (in thousand) 

2030 

2050 

Austria 
Belgium 
Bulgaria 
Cyprus 
Croatia 
Czech Republic 
Denmark 

243 
301 
- 
15 
- 
-82 
44 

123 

294 
353 
- 
17 
- 
-84 
57 

 
 
2030 

2050 

Estonia 
Finland 
France 
Germany 
Greece 
Hungary 
Ireland 
Italy 
Latvia 
Lithuania 
Luxembourg 
Malta 
Netherlands 
Poland 
Portugal 
Romania 
Slovenia 
Slovakia 
Spain 
Sweden 
EU27 
Source: COWI, Ecorys and NTUA (2022), Impact assessment support study 

19 
48 
-1,818 
1,842 
- 
-278 
44 
- 
-3 
-65 
-5 
- 
349 
1,025 
177 
321 
10 
- 
- 
375 
2,561 

22 
45 
-1,771 
1,921 
- 
-238 
55 
- 
-2 
-44 
-5 
- 
339 
1,182 
217 
356 
9 
- 
- 
453 
3,175 

The  adjustment  costs  for  citizens  due  to  the  shortening  of  the  administrative  validity  of  driving 
licences of group 1 to 5 years for drivers of the age of 65 years old or above are estimated at EUR 
300.6 million in 2030 and EUR 330.5 million in 2050 relative to the baseline for PM7. Expressed as 
present value over the 2025-2050 period, they are estimated at EUR 5,744.4 million. 

The change in costs with ‘age-dependent’ medical tests relative to the baseline, by Member State, is 
provided in Table 27. 

Table 27: Change in costs with the ‘age-dependent’ medical tests in PM7, relative to the baseline (in million) 

2030 

2050 

Austria 
Belgium 
Bulgaria 
Cyprus 
Croatia 
Czech Republic 
Denmark 
Estonia 
Finland 
France 
Germany 
Greece 
Hungary 
Ireland 
Italy 
Latvia 
Lithuania 
Luxembourg 
Malta 

8.5 
21.9 
- 
0.7 
- 
-1.7 
2.4 
0.8 
6.4 
-65.5 
248.6 
- 
-2.5 
2.2 
- 
-0.1 
-1.6 
-0.2 
- 

124 

10.3 
25.7 
- 
0.8 
- 
-1.7 
3.1 
0.9 
6.1 
-63.8 
259.3 
- 
-2.1 
2.7 
- 
-0.1 
-1.1 
-0.2 
- 

 
 
 
2030 

2050 

Netherlands 
Poland 
Portugal 
Romania 
Slovenia 
Slovakia 
Spain 
Sweden 
EU27 
Source: COWI, Ecorys and NTUA (2022), Impact assessment support study 

14.5 
43.2 
8.4 
8.7 
0.6 
- 
- 
5.3 
300.6 

14.1 
49.9 
10.3 
9.6 
0.5 
- 
- 
6.4 
330.5 

For the screening of fitness to drive for each driver renewing their driving licence independent of 
age, the approach is similar to PM6 and would result in an increase in the number of self-assessments 
in  BG,  CZ,  DE,  DK,  EE,  FR,  HR,  LU,  LT,  MT,  SI  and  SK.  However,  in  this  case  as  the 
self-assessment will be filled out with a general practitioner, some 16% of all self-assessments would 
result in a medical test,  drawing on the practices regarding periodic screening for  the UK271. The 
increase in the number of medical tests is estimated at  0.5 million in 2030 and 1 million in 2050 
relative to the baseline. The adjustment costs for citizens are estimated at EUR 36.2 million in 2030 
and EUR 75.2 million in 2050 relative to the baseline. Expressed as present value over the 2025-2050 
period, they are estimated at EUR 1,105.8 million relative to the baseline (in 2021 prices). 

For the vision test, also FR would be required to replace the ‘licence-plate self-test’ by a vision test 
(in addition to CY and NL which already do so in PM6), due to the mandatory nature of the measure. 
For FR the additional number of tests relative to the baseline are estimated at 1.7 million in 2030 and 
1.8 million in 2050 and the adjustment costs at EUR 27.2 to 136 million in 2030 and EUR 28.5 to 
142.3 million in 2050. Thus, the total adjustment costs for citizens for the vision test in PM7 (for CY, 
NL and FR) are estimated at EUR 33.1 to 165.7 million in 2030 and at EUR 34.6 to 173 million in 
2050  relative  to  the  baseline.  Expressed  as  present  value  over  the  2025-2050  period,  they  are 
estimated at EUR 622.1 to 3,110.7 million relative to the baseline (in 2021 prices). 

The total  adjustment  costs for citizens for the shortening  of the administrative validity  of driving 
licences of group 1 to 5 years for drivers of the age of 65 years old or above, for the screening of 
fitness to drive for each driver renewing its driving licence independent of age and for the vision test 
are  estimated  at  EUR  369.9  to  502.5  million  in  2030  and  EUR  440.4  to  578.8  million  in  2050. 
Expressed as present value over the 2025-2050 period, they are estimated at EUR 8,377.6 to 10,866.2 
million relative to the baseline (in 2021 prices). 

PM 8: Removal of the staging requirement to obtain a licence of category CE or DE 

Administrative cost savings for road transport operators 

In PM8, the removal of the requirement to hold a licence of category C or D to obtain a licence of 
category CE or DE is expected to lead to administrative costs savings for professional drivers that 
benefit road transport operators.  

Based on information from France and Germany, about 37% to 40% (FR and DE) of all C exams (C, 
C1E or C1E) concern CE exams. The professional drivers that have conducted a test for a CE licence 
had already obtained a C licence, which is currently required by the Directive. For D licences, no 

271  Source: https://www.nhs.uk/conditions/nhs-health-check/what-is-an-nhs-health-check-new/ 

125 

 
 
                                                 
information is available, but buses are generally less likely to drive with a trailer than heavy goods 
vehicles. To estimate the impact of the measure, it has been assumed that the number of C and D tests 
would decrease by 30% relative to the baseline. 

PM8 would lead to a reduction in the number of theoretical and practical tests required to obtain a 
CE or DE category licence, estimated at 469,349 in 2030 and 572,082 in 2050, relative to the baseline. 
The administrative costs savings for road transport operators in PM8 are thus estimated at EUR 44.8 
million in 2030 and EUR 53.8 million in 2050 relative to the baseline272. Expressed as present value 
over the 2025-2050 horizon (in 2021 prices), total  administrative costs savings  for  road transport 
operators are estimated at EUR 875.3 million in PO-B and PO-C. 

PM  9:  Flexibility  for  the  first  issuance  of  driving  licences  in  case  of  restrictions  related  to 
languages 

This  measure  would  only  affects  a  fairly  small  number  of  cases.  The  demand  for  tests  in  other 
languages is relatively small (for example, in Spain about 1.5% of all theoretical exams are conducted 
in another language) and the measure only affects Member States that do not allow for interpreters 
or facilitate a test conducted in another language. There are no significant impacts expected on costs 
although PM9 may result in some reduction of the hassle costs for citizens.  

PM 10: Mutual recognition of physical and mental assessment  

There are no significant impact on costs expected due to PM10.  

PM 11: New optional equivalence related to vehicles with limited maximum speed 

There are no significant impact on costs expected due to PM11.  

PM 12: Rules on the removal of code 70 

Administrative costs savings for citizens  

In PM12 the Code 70 will be removed from the licence when the driver has been holding an EU 
licence for at least 5 years and has not committed serious road traffic offenses. PM 12 is included in 
PO-C only. 

In the baseline, holders of a third country licence are restricted via Code 70. Other EU Member States 
may decide not to recognise the licence. As such, these holders may have to conduct a driving test 
(theoretical and practical) to be able to obtain an EU licence when changing residence. On an annual 
basis, some 8 to 9% of third country licence holders (with Code 70) change residence within EU.  

In PM12 (included in PO-C), the code 70 is assumed to be removed from the licence when the driver 
has  been  holding  an  EU  licence  for  at  least  5  years  and  has  not  committed  serious  road  traffic 
offenses. By implementing PM12 it is expected that fewer holders of a third country licence would 
conduct a driving test to obtain an EU licence that can also be exchanged when the holder changes 
residence. Thus, the number of tests is estimated to decrease by 7,235 in 2030 and 7,552 in 2050 
relative to the baseline. The administrative costs savings for citizens are estimated at EUR 1 million 

272  The average cost per theoretical test for a category C licence is estimated at EUR 42, based on data for 17 Member States, and the 
average cost per practical test at EUR 134. For category D licence, the average cost per theoretical test is estimated at EUR 43, 
based on data for 17 Member States, while the average cost per practical test at EUR 136. For the Member States for which data 
was not available, the average cost per test for the 17 Member States has been used. 

126 

 
                                                 
in 2030 and EUR 1.1 million in 2050 relative to the baseline. Expressed as present value over the 
2025-2050 period, they are estimated at EUR 19.3 million relative to the baseline (in 2021 prices) in 
PO-C. 

PM 13: New optional equivalence related to bus without passengers 

The measure is expected to lead to limited impact on costs savings as the holder of a driving licence 
of category C would be authorised to drive a bus without passengers on the territory of his or her 
issuing state, if that later has decided to  implement  this optional equivalence. However, the costs 
savings are not expected to be significant and it was not possible to quantify them.  

PM 14: Rules on the exchange of foreign driving licences 

PM14 is expected to lead to some limited costs savings for citizens. However, it was not possible to 
estimate the impacts on costs savings.  

4. IMPACTS BY POLICY MEASURE ON SAFETY 

This  section  explains  the  inputs  used  and  provides  the  assessment  of  the  impacts  of  the  policy 
measures included in the policy options on safety. Only the measures with significant impact, that 
have been quantified, are included. The synergies between the measures included in the options are 
already  captured  in  this  section.  A  qualitative  assessment  of  the  impact  on  road  safety  of  the 
remaining policy measures is provided in Annex 10.  

PMc1: Update of standards on skills and knowledge to be met for the first issuance of a driving 
licence 

The road safety impact PMc1 and in particular of the Hazard Perception Test (HPT) was estimated 
based on findings from the UK. Research from the UK indicate that drivers that have passed an HPT 
are 2.5% less likely to be engaged in an accident in the first three years after having passed this exam, 
when accidents  on all public roads are considered273. The study also  showed that the HPT would 
reduce the number of accidents in the first year of driving by 1.4%. A conservative approach has been 
used in  our  assessment,  drawing on the impact  assessment support study,  taking into account  the 
effect of the HPT in the first year of driving.  

This is used to estimate the impact of PMc1. However, as the data extracted from the CARE database 
consists of novice drivers with less than 5 years of experience, an adjustment was needed. This was 
done by considering that drivers in their first year of driving are more accident prone than drivers in 
years 2 to 5. More specifically, it was found that 46% of all driver fatalities occur within the group 
of novice drivers will less than 2 years of experience. It was further assumed that 55% of all fatalities 
of novice drivers with less than 2 years of experience are attributed to novice drivers with less than 
1 year of experience. This results in an estimated 0.4% reduction in the car fatalities in which novice 
drivers are involved, for countries that did not implement the HPT in the baseline (all MS except for 
Belgium274, Germany, Finland and the Netherlands275). The number of lives saved is thus estimated 
at 10 in 2030 and 8 in 2050 at EU level, relative to the baseline, while the number of serious injuries 

273  Table A5.10 from RSRR81 - Cohort II - A study of learner and new drivers. Volume 1 - main report. 
274  https://assets-global.website-files.com/604a00a4df74a7000318621d/607edfdbcec6a17747865d44_20-

3137_Goca_jaarverslag2019_NL_20200505-small.pdf  

275  European Commission, Directorate-General for Mobility and Transport, Vlakveld, W., Fernández-Medina, K., Oxley, J., et al., 

Study on driver training, testing and medical fitness : final report, Publications Office, 2017 (for DE, FI and NL). 

127 

 
                                                 
avoided at 96 in 2030 and 76 in 2050. PMc1 is part of all policy options and its impact is the same 
across options.  

PMc11: Improvement and simplification of rules on administrative validity 

In PMc11, the 15 years long administrative validity of driving licences for A and B categories will 
be made mandatory  and exclusive. As explained in  section 3 of Annex 4, the Directive currently 
requires an administrative validity period of 10 years, but allows Member States to also issue licence 
for 15 years. For Member States that are already issuing licences for 15 years by default (AT, CY, 
CZ,  DE, FI,  FR, EL,  LU, PL, PT, SK and DK) the measure would have no impact.  For all other 
Member States, the number of licences that would have to be renewed is estimated to decrease by 1.8 
million in 2030 and 3.7 million in 2050. 

This implies that in some Member States the number of medical checks for the renewal of the driving 
licences would be reduced relative to the baseline. A study for the Netherlands showed that people 
older than 70 were in 0.8% of cases deemed medically unfit to drive276. A larger group (36.2%) was 
deemed fit, however with restrictions.  In most  cases, these restrictions concerned requirements to 
wear glasses or not to drive during night time. It must be noted that most of the tested people that 
were  restricted  to  only  drive  with  glasses,  already  used  glasses  prior  to  medical  test.  Thus,  the 
imposed restriction was mainly of an administrative nature, with no significant impact on road safety. 
For this reason, for the assessment, only the people that are deemed unfit to drive are assumed to pose 
a real threat to road safety.  

For assessing  the impact of the measure on safety, it has been assumed that  if the number of the 
medical  checks  in  a  Member  State  is  reduced,  the  number  of  fatalities  in  which  unfit  drivers  are 
involved would increase by 0.8%. The increase in the number of fatalities at EU level is estimated at 
7 in 2030 and 5 in 2050 relative to the baseline, while the number of serious injuries avoided at 67 in 
2030 and 48 in 2050. 

PM1: Rules on training and probation periods - Recommendation on lifelong training  

The road safety impact of accompanied driving was derived based on findings from five countries 
that  have  implemented  the  system  (Germany277,  Sweden278,  Netherlands279,  France280  and 
Norway281). The studies show different effects, with a significant positive impact in Sweden (35% 
reduction in fatalities in which novice drivers with less than 2 years of experience are involved) and 
no significant impact observed in France, Netherlands and Norway. For Germany, the reduction in 
the number of fatalities in which novice drivers are involved was estimated at 23%. For assessing the 
impact of accompanied driving in PM1 the average of the five countries is used. To be conservative, 
the estimate has been further scaled down by 50%. In addition, based on data for the Netherlands, it 
has been assumed that 35% of all applicants for a B licence would make use of the possibility to 

276  https://www.rivm.nl/bibliotheek/rapporten/280001001.pdf  
277  Schade, F.-D. & Heinzmann, H.-J. (2011). Sicherheitswirksamkeit des Begleiteten Fahrens ab 17. Summative Evaluation. BASt-
Bericht Mensch und Sicherheit, Heft M 218. Bundesanstalt für Straßenwesen (BASt), Bergisch Gladbach. https://bast.opus.hbz-
nrw.de/opus45-bast/frontdoor/deliver/index/docId/544/file/M218.pdf  

278  Gregersen, N.P., Berg, H,-Y., Engström, I., Nolén, S., et al.  (2000). Sixteen years age limit for learner drivers in Sweden  - an 

evaluation of safety effects. In: Accident Analysis & Prevention, vol. 32, nr. 1, p. 25-35. 

279  https://swov.nl/system/files/publication-downloads/r-2015-11.pdf  
280  Page, Y., Ouimet, M.C. & Cuny, S. (2004). An evaluation of the effectiveness of the supervised driver training system in France. 
In: Proceedings of the 48th Annual Conference of the Association for the Advancement of Automotive Medicine AAAM, 13-15 
September 2004, Key Biscayne, Florida. p. 131-145. 

281  OECD & ECMT (2006). Young drivers: the road to safety. Joint OECD/ECMT Transport Research Centre, Paris. 

128 

 
                                                 
obtain the licence at the age of 17 and drive accompanied. Further correcting for the fact that the 
group of novice drivers below 5 years is used (as in PMc1), the road safety impact of accompanied 
driving in PM1 is estimated at a 0.9% reduction in the number of fatalities in which novice drivers 
are  involved.  No  impact  relative  to  the  baseline  was  assumed  for  MS  that  already  implement 
accompanied driving (BE, DE, FR, EL, IE, NL and SE)282.  

For the strict rules related to driving under influence (zero tolerance) for novice drivers, the road 
safety impact was derived by considering a study for Belgium283 on the impact of introducing an 
alcohol limit for novice  drivers. The study found that this  measure  could decrease the number of 
fatalities in Belgium by 2 to 4. The study for Belgium considered all drivers in the age group of 18-
24, as a proxy for novice drivers. Using the lower estimate and the total number of fatalities in which 
novice drivers are involved in Belgium, this implies a reduction by 1.2% in fatalities in which novice 
drivers are involved. Further correcting for the group of novice drivers with experience of less than 
five  years, the impact of strict rules  related to driving under influence (zero tolerance) for novice 
drivers is estimated at a 0.9% reduction in the number of fatalities for novice drivers. In addition, the 
measure is assumed to have no impact relative to the baseline for MS that already have in place a 
probation period284 (AT, DE, FR, HR, IE, IT, LV, NL PT, SI). 

PM1 is jointly implemented together with PMc1 in the PO-B and PO-C. Both measures target the 
same group of drivers (i.e. novice drivers), however they have a different and complementary impact. 
However, as the same fatality cannot be reduced twice, the impact of measure PM1 is only applied 
to fatalities in which novice drivers are involved that are not prevented by PMc1. The reduction in 
the number of fatalities at EU level due to PM1 is estimated at 32 in 2030 and 29 in 2050 relative to 
the baseline, while the number of serious injuries avoided at 306 in 2030 and 277 in 2050.  

PM4: Mutual recognition of driving disqualifications 

The estimation of the number of driving disqualifications resulting from driving under the influence 
of alcohol has been explained in the previous section of Annex 4, in relation to the impacts on costs. 

Road safety impacts due to driving disqualifications resulting from driving under the  influence of 
alcohol. In order to estimate the impacts on road safety, first the share of fatalities attributed to alcohol 
was  estimated.  A  recent  study  estimated  that  some  19%  to  26%  of  all  fatalities  are  attributed  to 
alcohol, with an average estimate of 22.5%285. The share of fatalities attributed to alcohol in the total 
number of fatalities is assumed to remain constant over time in the baseline scenario.  

The impact has been estimated by considering: (i) the relative increase in the driving disqualifications 
resulting from driving under the influence of alcohol relative to the baseline; (ii) the reduction in the 
crash rate as a result of suspending licences, estimated at 17% based on road safety cube estimates286. 
In addition, an adjustment has been made using the share of fatalities in which a foreign registered 

282  EReg (2022) The Vehicle and Driver Chain in Europe 2022, EReg – Association of European Vehicle and Driver Registration 

Authorities, Brussels. 

283  Nathalie Moreau, Heike Martensen, Stijn Daniels, Lowering the legal alcohol limit in Belgium? – Potential effects on the number 

of traffic victims, Brussels, Belgium: Vias institute – Knowledge Centre Road Safety 
https://www.vias.be/publications/Verlaging%20van%20de%20wettelijke%20alcohollimiet%20in%20Belgi%C3%AB/Lowering
_the_legal_alcohol_limit_in_Belgium.pdf  

284  ETSC PIN Flash Report 41 https://etsc.eu/wp-content/uploads/PIN-Flash-41_web_FINAL.pdf  
285  European Commission, Directorate-General for Mobility and Transport, Modijefsky, M., Janse, R., Spit, W., et al., Prevention of 
the  European  Union,  2022, 

influence  of  alcohol  and  drugs,  Publications  Office  of 

driving  under 
https://data.europa.eu/doi/10.2832/218096. 

the 

286  https://www.roadsafety-dss.eu/assets/data/pdf/synopses/Licence_suspension_27062017.pdf  

129 

 
                                                 
vehicle is involved in relation to the number of traffic offences in which a foreign registered vehicle 
is  involved.  This  adjustment  has  been  performed  to  correct  for  possible  differences  in 
offence/accident ratios for foreign drivers that generally drive on safer roads, such as highways, and 
draws on data from the CARE database and the impact assessment support study for the revision of 
the CBE Directive287. In addition, PM4 is jointly implemented together with PMc1 and PM1 in PO-B. 
A correction is made to reflect the fact that PM1 and PM4 apply to different drivers groups (i.e. while 
PM1 is mainly targeted at novice drivers, PM4 addresses all drivers). In addition, as the same fatality 
cannot be reduced twice, the impact is assessed for fatalities involving novice drivers that are not 
prevented by PMc1 and PM1.  

Road safety impacts due to driving disqualifications resulting from speed driving. The impact has 
been estimated by considering: (i) the relative increase in the driving disqualifications resulting from 
severely speeding relative to the baseline; (ii) the impact of speed enforcement drawing on Elvik et 
al. (2015)288. It is estimated that 0.9% of all speeding offences are sufficiently severe to risk losing 
the licence289. The estimated impact of traffic rules enforcement draws on Elvik et al. (2015)290. This 
study, conducted in the framework of the Road Safety Cube, found that a 1% increase in the speed 
enforcement  level  is  associated  with  0.6%  to  0.7%  decrease  in  the  number  of  road  accidents.  In 
addition,  an  adjustment  has  been  made  using  the  share  of  fatalities  in  which  a  foreign  registered 
vehicle is involved in relation to the number of traffic offences in which a foreign registered vehicle 
is involved, drawing on data from the CARE database and the impact assessment support study for 
the  revision  of  the  CBE  Directive291.  This  adjustment  has  been  performed  to  correct  for  possible 
differences in offence/accident ratios for foreign drivers that generally drive on safer roads, such as 
highways.  As  the  same  fatality  cannot  be  prevented  twice,  the  impact  is  assessed  for  fatalities 
involving novice drivers that are not prevented by PMc1, PM1 and PM4 (alcohol). The reduction in 
the number of fatalities at EU level is estimated at 5 in 2030 and 3 in 2050 relative to the baseline, 
while the number of serious injuries avoided at 48 in 2030 and 29 in 2050. 

PM5: Rules on consequences of penalty points for non-residents - Rules on rehabilitation in 
case of a change of normal residence 

For PM5, the assessment of the road safety impacts follows a similar approach as for PM4. However, 
a lower BAC-limit was considered and thus a higher number of offences can be successfully enforced. 
In addition, the impact on the crash rates has been assumed at 16% based on the Road Safety Cube 
linked to the introduction of the penalty points system292. As the impact is slightly smaller but the 
affected group larger, the impact of PM5 is expected to be slightly higher than that of PM4.  

In addition, PM5 is jointly implemented together with PMc1 and PM1 in PO-C. A correction is made 
to  reflect  the  fact  that  PM1  and  PM5  apply  to  different  drivers  groups  (i.e.  while  PM1  is  mainly 
targeted  at  novice  drivers,  PM5  addresses  all  drivers).  In  addition,  as  the  same  fatality  cannot  be 
reduced twice, the impact is assessed for fatalities involving novice drivers that are not prevented by 
PMc1 and PM1. The reduction in the number of fatalities at EU level is estimated at 9 in 2030 and 7 

287  Ecorys  et  al.  (2022),  Impact  Assessment  support  study  for  the  revision  of  Directive  (EU)  2015/413  facilitating  cross-border 

exchange of information on road-safety-related traffic offences 

288  Elvik,  R.  (2015).  Methodological  guidelines  for  developing  accident  modification  functions.  Accident  Analysis  &  Prevention 

80(3), 26-36. Doi: 10.1016/j.aap.2015.03.038. 

289  https://www.verkeersstatistieken.federalepolitie.be/verkeersstatistieken/interactief/  
290  ibid. 
291  Ecorys  et  al.  (2022),  Impact  Assessment  support  study  for  the  revision  of  Directive  (EU)  2015/413  facilitating  cross-border 

exchange of information on road-safety-related traffic offences 

292  Goldenbeld, Ch (2017), Demerit point system, European Road Safety Decision Support Systems, developed by the H2020 

project SafetyCube.  

130 

 
                                                 
in 2050 relative to the baseline, while the number of serious injuries avoided at 86 in 2030 and 67 in 
2050. 

PM6: Rules on simple medical screening  

Shortening the administrative validity of driving licences of category A and B licences to 5 years for 
drivers of the age of 70 years old or above, to enable more frequent medical screening. A study for 
the Netherlands showed that people older than 70 were in 0.8% of cases deemed medically unfit to 
drive293.  A  larger  group  (36.2%)  was  deemed  fit,  however  with  restrictions.  In  most  cases,  these 
restrictions concerned requirements to wear glasses or not to drive during night time. It must be noted 
that most of the tested people that were restricted to only drive with glasses, already  used glasses 
prior to medical test. Thus, the imposed restriction was mainly of an administrative nature, with no 
significant impact on road safety. For this reason, for the assessment, only the people that are deemed 
unfit  to  drive  are  assumed  to  pose  a  real  threat  to  road  safety,  which  represents  a  conservative 
assumption. The same share of people unfit to drive is assumed for the age group 50 to 70 years old, 
in lack of more detailed information.  

The change in the number of medical check due to PM6 are provided in section 3 of Annex 4. At EU 
level, the reduction in the medical checks is estimated at 3.6 million in 2030 and 3.4 million in 2050 
relative to the baseline.  

For assessing the impact of the measure on safety, it has been assumed that  if the number of the 
medical checks in a Member State is reduced, the number of fatalities in which drivers of 50 to 70 
years old are involved would increase by 0.8%. Member States that do not test based on age, or adopt 
a higher age limit than 70, are unaffected by the measure. Thus, as explained in section 3 of Annex 
4, the measure is expected to only have an impact for DK, FR, HU, LT, LV, CZ, LU, EL, ES, IT and 
SK.  

Medical  screening  at  renewal,  based  on  a  self-assessment  triggering  assessments  by  a  general 
practitioner if required. Several MS (AT, BE, CY, FI, IE, NL, PT and SE) already apply the measure 
and thus PM6 would not have an impact on them relative to the baseline. Other MS (EL, ES, HU, IT, 
LV, PL, RO) require a medical test at the renewal of their driving licence and thus PM6 would not 
have an impact on them. For the remaining MS (BG, CZ, DE, DK, EE, FR, HR, LU, LT, MT, SI, 
SK), the increase in the number of medical tests is estimated at 0.2 million in 2030 and 0.5 million 
in 2050 relative to the baseline, as explained in section 3 of Annex 4.  

According to results of the survey conducted in the context of the impact assessment support study, 
a range of 5-15% of all traffic accidents were attributed to driver’s medical condition. This range is 
confirmed by multiple sources: the ETSC PIN Flash Report 40 (2021) indicates that, in Finland, 16% 
of all fatal collisions are attributed to a driver illness294. In France, close to 4% of total accidents was 
attributed to medication295. A Danish report296 revealed that, during the period 2017-2019, 9% of 
traffic accidents  was  attributed to  impaired physical  conditions  and 1% to an unbalanced state of 
mind297. Based on data available for 9 Member States, the average share of fatalities attributed to 

293  https://www.rivm.nl/bibliotheek/rapporten/280001001.pdf  
294  https://etsc.eu/wp-content/uploads/PIN-Flash-40_Final.pdf  
295  La sécurité routière en France Bilan de l’accidentalité de l’année (2019) 
296  Ulykkesfaktorer in Vejdirektoratet (2020) Dødsulykker 2019 Årsrapport 
297  https://www.statistik.at/fileadmin/publications/Strassenverkehrsunfaelle-2021.pdf  

131 

 
                                                 
driver’s medical condition is estimated at 8%. This is used to derive the number of fatalities that have 
likely resulted from medically unfit drivers. 

In addition, as explained in section 3 of Annex 4, it is assumed that some 8% of all self-assessments 
would result in a medical test, drawing on the practices regarding periodic screening for the UK298. 
Information from Belgium299, shows similar order of magnitude with 10% of all drivers that were 
initially referred to a self-assessment being unfit to drive. To provide for a conservative estimate, it 
is assumed that around half of the number of road fatalities in which experienced drivers are involved 
are due to medical fitness. As explained above, only BG, CZ, DE, DK, EE, FR, HR, LU, LT, MT, SI 
and SK are affected by this measure.  

For the vision test, a paper by ECOO300 shows that some 10% of all people are expected to have 
inadequate vision and as such should not be able to drive a vehicle without accompanying measures 
such as the requirement to wear glasses. Lack of vision is shown to increase the probability of being 
involved  in  an  accident  by  9%  relative  to  people  that  have  adequate  vision301.  For  assessing  the 
impacts of the measure, it has been conservatively assumed that the benefits would only occur during 
the first year of driving, after obtaining the licence.  

PM6 is assumed to be implemented jointly with PMc1, PM1 and PM4. As the same fatality cannot 
be  reduced  twice,  the  impact  is  assessed  for  fatalities  involving  drivers  that  are  not  prevented  by 
PMc1 and PM1 and PM4. The reduction in the number of fatalities at EU level is estimated at 11 in 
2030 and 9 in 2050 relative to the baseline, while the number of serious injuries avoided at 105 in 
2030 and 85 in 2050. 

PM7: Rules on advanced medical screening 

For PM7 a similar approach is used as for PM6. In relation to the shortening of the administrative 
validity to 5 years for drivers of the age of 65 years old or above, for assessing the impact of the 
measure on safety, it has been assumed that if the number of the medical checks in a Member State 
is reduced, the number of fatalities in which drivers of 65 to 70 years old are involved would increase 
by 0.8%. However, the impacts are different in PM7 relative to PM6 because the groups of Member 
States that reduce the number of medical checks is different, as explained in section 3 of Annex 4. 
Similar approach as in PM6 has been used for assessing the safety impacts of the medical screening 
at renewal of a driving licence. The impact is however estimated to be higher due to the fact that the 
self-assessment is conducted with a CP. The same approach as in PM6 has also been used for the 
vision test. However, in PM7 also FR adopt the vision test as explained in section 3 of Annex 4 and 
thus the impacts are larger.   

Finally, PM7 is assumed to be implemented jointly with PMc1, PM1 and PM5. As the same fatality 
cannot be reduced twice, the impact is assessed for fatalities involving drivers that are not prevented 
by PMc1 and PM1 and PM5. The reduction in the number of fatalities at EU level is estimated at 35 

298  Source: https://www.nhs.uk/conditions/nhs-health-check/what-is-an-nhs-health-check-new/; In the UK, the assessment is 

performed by a professional. Under PM6, a self-assessment is assumed without the involvement of a GP. For this reason it is 
assumed that the procedure is less effective and thus some people that might be medically unfit would not be identified. 
Therefore, the figure for UK (16.1%) is scaled down by 50% to account for this. 

299  https://www.vias.be/publications/Statistisch%20Rapport%202018%20-

%20Rijvaardigheid%20en%20rijgeschiktheid/Statistisch_rapport_2018_-_Rijvaardigheid_en_rijgeschiktheid.pdf  
300  https://www.ecoo.info/wp-content/uploads/2017/01/Visual-Standards-for-Driving-in-Europe-Consensus-Paper-January-

2017....pdf  

301  https://www.toi.no/getfile.php/135780-1176216112/Publikasjoner/T%C3%98I%20rapporter/2003/690-2003/690-2003-el.pdf  

132 

 
                                                 
in 2030 and 29 in 2050 relative to the baseline, while the number of serious injuries avoided at 334 
in 2030 and 277 in 2050. 

A summary of the impacts of the measures on the number of fatalities and serious injuries is provided 
in Table 28. 

Table 28: Change in the number of fatalities and serious injuries, by measure, relative to the baseline  

Total fatalities 

PMc1 
PMc11 
PM1 
PM4 
PM5 
PM6 
PM7 

Total serious injuries 

PMc1 
PMc11 
PM1 
PM4 
PM5 
PM6 
PM7 

PO-A 

Difference to the baseline 
PO-B 

PO-C 

2030 
-3 
-10 
7 

2050 
-3 
-8 
5 

2030 
-51 
-10 
7 
-32 
-5 

2050 
-44 
-8 
5 
-29 

-3    

2030 
-79 
-10 
7 
-32 

2050 
-68 
-8 
5 
-29 

-29 
-96 
67 

-28 
-76 
48 

-11 

-9    

-488 
-96 
67 
-306 
-48 

-419 
-76 
48 
-277 

-29    

-105 

-85    

-9 

-7 

-35 
-755 
-96 
67 
-306 

-29 
-649 
-76 
48 
-277 

-86 

-67 

-277 
Total fatalities and injuries avoided 
-717 
Source: COWI, Ecorys and NTUA (2022), Impact assessment support study; Note: the negative sign denotes a decrease 
in the number of fatalities and serious injuries and the positive sign an increase relative to the baseline.  

-334 
-834 

-539 

-463 

-32 

-31 

133 

 
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
 
 
ANNEX 5: DISCARDED POLICY MEASURES 

During the Impact Assessment process, a number of possible policy measures have been discussed with the key stakeholders and finally discarded, as 
explained below.  

Policy measure 

and 

testing 

Rules  on  mandatory  lifelong 
training 
are 
introduced to ensure adequate 
skills  and  knowledge  of 
drivers  in  the  context  of  fast-
changing technologies 

Relevant 
Driver 

PD1 

Short description 

Reason for discarding 

Lifelong  training  or  testing  is 
made  mandatory  either  at  the 
renewal of the driving licences or 
at purchase of a new vehicle. 

The consultation activities identified that benefits in road safety can be expected by 
a better use of advanced technologies such as ADAS, but the knowledge and skills 
required vary significantly from one equipment to another. In addition, authorities 
question the consequences for a driver not complying with these rules. Therefore, 
the measure has been discarded due to lack of effectiveness and political feasibility.  

Amendments to the definitions 
of  vehicle  categories 
for 
motorcycles 

PD1 

Categories  A1,  A2  and  A  will 
include 
combination  of 
the 
motorcycles with a trailer. 

Introduction  of  categories  for 
agricultural vehicles 

PD5 

4 

of 

Directive 
Article 
2006/126/EC  will  be  amended  to 
include  a  definition  of  one  or 
several categories for agricultural 
vehicles, including minimum age.  

The consultation activities identified a demand expressed solely by the users.  
The current rules applicable in the EU302 vary significantly from one Member State 
to another and are often linked to other traffic rules, such as speed limits.  
In addition, the absence of type approval rules for motorcycle trailers at EU level 
does not allow to identify the types of trailers to be authorised.  
The amendment would therefore go beyond the legal basis of the Directive. 

The consultation activities identified a demand expressed solely by one stakeholder 
representing Agricultural, Rural and Forestry Contractors.  
The current rules applicable in the EU vary significantly from one Member State to 
another and are often linked also to professional matters, for example with different 
conditions applicable to agricultural and non-agricultural uses.  
The amendment would therefore go beyond the legal basis of the Directive.  

302  https://www.femamotorcycling.eu/consumer-information/riding-with-a-trailer/  

134 

 
                                                 
Policy measure 

Mutual recognition of training 
/ theoretical test 

Relevant 
Driver 

PD1 

Rules  for  Light  Commercial 
Vehicles (LCV) drivers 

PD1 

Short description 

Reason for discarding 

Training  started  in  a  MS  will  be 
taken  into  account  in  other  MS 
requiring  a  minimum  training  to 
be able to pass the driving test 
Theoretical  test  will  be  mutual 
recognised  for  the  purpose  of 
obtaining  a  driving  licence  after 
having 
the  normal 
transferred 
residence to another EU MS. 

The  rules  on  training  are  defined  at  national  level  and  are  very  heterogeneous, 
including regarding the training set-up and trainers. Exchanges with authorities have 
shown that establishing equivalences would be extremely complex in the absence 
of a common reference.  
Regarding theoretical test, certain aspects covered are the same everywhere in the 
EU.  However,  considering  the  differences  between  road  traffic  rules,  the  mutual 
recognition would create an additional risk on novice drivers which are the most 
affected by road accidents.  
The measure has been discarded because of limited feasibility and effectiveness. 

A  Union  code  will  be introduced 
and  required  for  LCV  drivers 
subject to new rules on driving and 
resting time. 
Specific  training  and  potentially 
assessment of medical fitness will 
be required to obtain the marking 
of the code. 

While rules on driving and resting times will be introduced for some LCV drivers, 
consultation  activities  have  not  allowed  to  identify  a  demand  to  ensure  the 
knowledge of these rules by the drivers concerned. 
In addition, the potential problems to be  settled by such measures have not been 
fully confirmed by the support study. The implementation would result in significant 
administrative  burden,  considering  that  the  verification  would  likely  have  to  be 
conducted in a more frequent manner than the renewal of licences of category B. 
The measure has been discarded because of limited feasibility and effectiveness. 

Changes  to  the  requirements 
on minimum age  

PD4 

The minimum age(s) required for 
obtaining  a  driving  licence  are 
lowered. 

The  consultation  activities have  shown limited interest in reducing  the  minimum 
ages, in particular due to the resulting implications on road safety. 
Data from the US303 show that the risk of motor vehicle crashes is higher among 
teens aged 16–19 than among any other age group.  
Road  safety  organisations  also  indicated  to  be  against  this  measure  during 
Workshop #1, and no Member State indicated to be in favour during the workshop.  
Thereby, the measure is discarded due to limited relevance and acceptance among 
stakeholders. 

303  https://www.cdc.gov/transportationsafety/teen_drivers/teendrivers_factsheet.html  

135 

 
                                                 
Policy measure 

Removal of code 70 

Relevant 
Driver 

PD5 

Short description 

Reason for discarding 

Under this measure, an exchanged 
licence is no longer issued with a 
Code  70.  This  would  mean  that 
any  person  with  an  exchanged 
have 
licence  mutually 
recognised  in  all  EU  Member 
States. 

this 

Many Member States in Workshop #2 indicated to be against this measure because 
they would like to keep the possibility not to exchange driving licences obtained in 
exchange of a licence issued by a third country they consider not being at the level 
of the EU from a road safety point of view.  
Thereby, the measure is discarded due to limited political feasibility. 
However, code 70 will not be issued in case of third countries considered at the same 
level of road safety (see Retained measures, PM 14)  

Removal  of 
access scheme for A licences 

the  graduated 

PD1 
PD4 

The requirements to hold a driving 
licence of category A1 or A2 for at 
least  two  years  before  passing  a 
test  for  the  category  A2  or  A  for 
young drivers would be removed.  

Specific  rules  to  deal  with 
language related issues  

PD4 

The  measure  would 
require 
Member  States 
to 
provide 
theoretical 
in 
tests 
all  EU 
an 
languages  or 
interpreter  in  order  to  overcome 
the language barrier. 

allow 

to 

Motorcyclist associations argue that the graduated access scheme for A licences is 
not proportionate. Road safety organisations are against the simplification/removal 
of the graduated access scheme. Furthermore, France indicated during the workshop 
that it experimented with a simplified approach to A-licences, but that this pilot was 
stopped due to a high number of fatalities. Thereby, removing the graduated access 
scheme  is  expected  to  deteriorate  road  safety,  and  the  political  feasibility  of  this 
measure might be problematic.  
Thereby,  the  measure  is  discarded  due  to  potential  increase  in  external  costs 
(increase in fatalities) and limited political feasibility.  

Member States have mixed experiences with the use of interpreters. Some allow for 
interpreters or translate the theoretical tests in other languages. Others have negative 
experiences  with  interpreters  as  they  might  result  in  fraud  (and  thereby  stopped 
allowing the use of interpreters). Due to the mixed appetite for the measure, political 
feasibility is expected to be problematic for the measure allowing interpreters.  
Some Member States already make the theoretical test available in other languages, 
but  no  Member  States  (to  our  knowledge)  offers  the  theoretical  test  in  all  EU 
languages.  Member  States  that  also  make  the  theoretical  test  available  in  other 
languages  indicate  that  only  a  (very)  small  number  of  people  make  use  of  this. 
Translating all theoretical questions into 23 EU languages is associated with a large 
cost and the benefits are likely small. Thereby, the measure to have the tests in all 
EU languages is discarded due to limited effectiveness and efficiency.  

136 

 
Policy measure 

Harmonise  road  traffic  rules 
and applicable sanctions 

Relevant 
Driver 

PD2 

Introduce 
harmonised 
a 
system  for  penalty  points  in 
the Directive 

PD2 

Require  novice  drivers 
to 
attend a driver refresher course 

PD 1 

Short description 

Reason for discarding 

of 

In  order  to  enable  the  mutual 
driving 
recognition 
disqualifications,  the  road  traffic 
rules, 
threshold  and 
consequences  of  offenses  would 
be harmonised. 

including 

to 

Under this measure, the relation of 
penalty 
driving 
points 
is  harmonised 
disqualifications 
across the EU. This system would 
harmonise  the  existing  penalty 
point  mechanisms 
in  Member 
States  and  specify  the  number  of 
penalty points that an offender can 
receive (possibly within a certain 
time  frame),  before  a  driving 
disqualification is imposed. 

Novice  drivers  are  required  to 
attend a driver refresher course six 
to  nine  months  after  they  have 
received 
licence.  The 
refresher  course  lasts  about  few 
hours  and  consists  of  theoretical 
and practical training. 

their 

Although this measure might have significant positive impacts on road safety and 
the mutual recognition of sanctions, the political feasibility is likely absent. Also, 
the  legal  feasibility  would  highly  likely  be  problematic,  due  to  different  legal 
regimes in MS and due to limited EU intervention in this area.  

The  measure is  unlikely  because  it  is not  legally  feasible (incl. from  subsidiarity 
point of view) – same as above. 

The views with this system are mixed, with some arguing that the costs and efforts 
from novice drivers to attend the refresher course are disproportionate and others 
arguing that the benefit for road safety exist. Member States currently already have 
the possibility to require these refresher courses and some are using this possibility, 
but some Member States would consider this measure not to be proportionate.  
Therefore, 
proportionality.  

limited  political  feasibility/ 

is  discarded  due 

the  measure 

to 

Introduce  standards 
to  be 
complied  with  by  driving 
schools and instructors  

PD1 

establishing 

By 
minimum 
standards for driving schools and 
instructors, it is expected that the 
quality of training will increase.  

Most Member States have already established such standards which are adapted to 
national specificities.  
The views expressed in workshop #1 and at the committee on driving licences held 
in May 2022 have underlined business difficulties encountered by driving schools 

137 

 
Policy measure 

Relevant 
Driver 

Short description 

Reason for discarding 

Introduced rules on the content 
of driver training 

PD1 

By  definition  the  content  of  the 
training,  it  is  expected  that  the 
quality of training will increase. 

Introduce  rules  for  former 
holders of EU driving licences 
residing 
in  EU  overseas 
territories 

PD5 

These drivers would be issued (at 
their  request)  a  driving  licence 
with  a  specific  EU  code.  The 
driving  licence  would  be  valid 
only  when  presented  with  the 
driving  licence  issued  by  the 
overseas territory. 

because  of  a  shortage  of  instructors  and  COVID-19.  European  standards  would 
consequently be low and result in marginal effects. 
Therefore,  the  measure  is  discarded  due  to  limited  political  feasibility  and 
effectiveness. 

Most of the Member States have already established such rules which are aiming to 
prepare  to  the  driving  test,  but  which  also  are  adapted  to  national  specificities 
(e.g. environment such as icy roads and road traffic rules) and general objectives on 
road safety at national level.  
The views expressed in workshop #1 and at the committee on driving licences held 
in May 2022 have underlined very inhomogeneous approaches. The measure would 
therefore  have  either  to  provide  a  very  large  flexibility  or  to  require  changes  to 
training schemes which are considered performant.  
Therefore, the measure is discarded due to limited proportionality, efficiency and 
effectiveness. 

This measure would address problems reported by Denmark on former holders of 
driving licences issued by Denmark who are now residing in Greenland. 
The  number  of  concerned  persons  seems  very  limited:  a  few  hundred  people 
travelling in the EU (abroad Denmark). 
Therefore, the measure is discarded due to limited proportionality and potential risk 
on road safety in case of driving disqualifications.  

138 

 
ANNEX 6: RETAINED POLICY MEASURES 

This annex presents the policy measures that have been retained to be included in policy options. First, the measures common to all policy options are 
presented. The second table provides the policy measures additionally included in PO-B and/or PO-C.  

Policy measures common to all policy options 

Driver  Policy measure 

Short description 

Link to a specific 
objective 

PD1 

PMc1:  Update  of  standards  on  skills 
and  knowledge  to  be  met  for  the  first 
issuance of a driving licence. 

PMc2: Introduction of rules to remove 
restrictions associated to automatic gear 
transmission.  

PMc3: Amendments to the definitions 
of vehicle categories for cars and vans 
(maximum mass). 

PMc4:  Improvement  of  RESPER  for 
the purpose of enforcement  

PD2 
PD4 
PD5 

The standards to be met for obtaining a driving licence will be updated.  
A driver hazard perception test will have to be conducted, including by use of simulators.  
Knowledge of risk factors related to micro mobility means and of safety of alternatively 
fuelled vehicles will be assessed. 
Knowledge and potentially skills related to advanced driving assistance systems and other 
automation aspects of the vehicle will be assessed.  

SO1 

Drivers  who  passed  their  driving  test  with  an  automatic  gear  vehicles  will  be  able  to 
remove the associated restriction on their driving licences (code 78).  
To  remove  the  restrictions,  they  will  have  to  follow  a  certified  training  or  to  pass 
successfully a short practical test, potentially with simulators. The test and the training will 
be conducted on a vehicle with manual transmission and will focus on skills dependent on 
the type of vehicle’s transmissions.  

Category B will include alternatively-fuelled vehicles of a maximum mass not exceeding 
4,25t, without a trailer. 

Requirements on RESPER will be introduced. They will specify the response time to be 
met when answering to requests and they will allow also to improve the data quality.  
Additional  information  will  be  exchanged,  in  particular  in  relation  to  driving 
disqualifications. 

SO1 
SO3 

139 

 
 
Driver  Policy measure 

Short description 

Link to a specific 
objective 

PD3 

PMc5: Update of standards on physical 
and  mental  fitness  to  be  met  for  the 
issuance of driving licences 

Requirements  related  to  diabetes  will  be  updated  taking  into  account  the  evolution  of 
medical care for this disease (for example, the frequency of the physical fitness assessment 
will be reduced from every 5 years to every 10 years).  

SO2 

PMc6:  New  rules  on  the  use  of 
to  mitigate  medical 
technologies 
unfitness  

When a person does not meet the standards on physical and mental fitness, a driving licence 
may  be  issued  to  him  or  her  with  the  obligation  to  use  a  technology  that  mitigates  the 
unfitness to drive (e.g. alcohol interlock)  

PD4 
PD5 

PD5 

PMc7:  Establishment  of  a  knowledge 
management  Platform  for  authorities 
regarding physical and mental fitness to 
drive 

PMc8:  Clarification  of  the  concept  of 
normal residence 

An  expert  group  will  be  established  and  annual  meetings  will  be  organised  to  allow 
authorities to share information and best practices in relation physical and mental fitness 
to drive (e.g. screening, assessment) 

The concept of normal residence will be developed to specify how the normal residence 
should  be  determined  during  the  6  first  months  of  establishment  in  a  new  country, 
including certain special cases  where two or more Member States consider they can be 
issuing authority. 

SO3 

PMc9:  Introduction  of  the  EU  mobile 
driving licence 

An EU digital driving licence will be introduced, based on ISO18013-5 and on eIDAS 
features.  Mobile  driving  licences  will  be  recognised  from  2026  and  will  be  issued  by 
default from 2028. 

PMc10: Introduction of a possible QR 
code on the physical licence in the areas 
reserved for microchip     

It will be possible to print a QR code in the space reserved on physical driving licences for 
microchips. It will provide access to additional information, not displayed on the physical 
driving licence.  

Improvement 

PMc11: 
simplification 
administrative validity. 

of 

rules 

and 
on 

The 15 years long administrative validity of driving licences for A and B categories will 
be made mandatory and exclusive.  
MS will be able to issue driving licences with an administrative validity not exceeding that 
of the residence permit of the (foreign) holder304. 

304  In a similar but more effective manner than Regulation (EU) 2020/698 and Regulation (EU) 2021/567. 

140 

 
 
 
 
                                                 
Driver  Policy measure 

Short description 

PMc12: Mutual recognition of optional 
equivalences  –  New  equivalence 
applicable to small bus combined with 
a trailer  

Optional equivalence will be mutually recognised. For that purpose, an EU code will be 
introduced for each of the optional equivalence of the Directive. 
A licence granted for categories D1 and CE shall be valid to drive vehicles in category 
D1E. 

Policy measures included in options PO-B and/or PO-C 

Driver 

Policy measure 

Short description 

PD1 
PD2 

PM1: Rules on training and probation 
periods 
on 
lifelong training  

-  Recommendation 

Rules  on  accompanied  driving  for  drivers  who  are  between  17  and  18  years  old  after 
passing the driving test will be introduced for categories B and C. It will include a specific 
EU code and standards applicable to accompaniers. It will require to reduce for this specific 
case the minimum age from 18 to 17 years old to be professionally qualified (Directive 
(EU) 2022/2561) 
A probation period of a minimum of 2 years will be established for novice drivers. It will 
be subject to strict rules related to driving under influence (zero tolerance) and potentially 
additional rules and/or restrictions defined by each MS. 
A recommendation will be adopted for lifelong training, with the objective to maintain 
drivers’ skills and knowledge on advanced technologies. 

Link to a specific 
objective 

Link  to  a  specific 
objective 

SO1 

PD1 

PM2:  Amendments  to  the  definition 
of  the  mopeds’  category  to  include 
certain micro mobility means 

The category AM will include all vehicles with a speed between a maximum speed of 25 
and 45 km/h, including micro-mobility means. It will not cover vehicles with a maximum 
speed below 25 km/h 

SO1 

PM3: Introduction of a new category 
for  tractors  -  amendment  to  the 
definition of the small bus category  

The mutual recognition of national licences for tractors will be introduced.  
The number of maximum passengers for vehicles of category D1 will be increased from 
16 to 22. 

141 

 
 
 
Driver 

Policy measure 

Short description 

Link  to  a  specific 
objective 

PD2 

PM4:  Mutual  recognition  of  driving 
disqualifications  

Driving  disqualifications  resulting  from  specific  offenses  (excessive  speed  driving  and 
driving under the influence of alcohol) will be mutually recognised. 

SO1 

PM5:  Rules  on  consequences  of 
penalty  points  for  non-residents  - 
Rules  on  rehabilitation  in  case  of  a 
change of normal residence  

PD3 

PM6:  Rules  on  simple  medical 
screening 

PM7:  Rules  on  advanced  medical 
screening  

Penalty points will be also applied to non-residents and driving disqualification resulting 
from penalty points system should be mutually recognised.  

Non-binding  guidelines  will  be  established  for  assessing  applicants’  vision  for group  1 
drivers. 
Medical  screening  will  be  mandatory  at  renewal  for  group  1  drivers,  based  on  a  self-
assessment triggering assessments by a general practitioner and/or a specialist if required.  
Administrative  validity  of  driving  licences  of  group  1  will  be  shortened  to  5  years  for 
drivers of the age of 70 years old or above to enable more frequent medical screening. 
An instrument will be established to prepare training material related to medical screening 
for general practitioners (in all EU languages). 

SO2 

Applicants’ vision will be checked by certified professionals for group 1 drivers. 
Medical  screening  will  be  mandatory  at  renewal  for  group  1  drivers,  based  on  a  self-
assessment filled out with a general practitioner triggering specific assessments if required.  
Administrative  validity  of  driving  licences  of  group  1  will  be  shortened  to  5  years  for 
drivers of the age of 65 years old or above to enable more frequent medical screening. 
An instrument will be established to prepare training material related to medical screening 
for general practitioners (in all EU languages). 

PD4 

staging 
PM8:  Removal  of 
requirement  to  obtain  a  licence  of 
category CE or DE  

the 

The requirement to hold a licence of category C or D to obtain a licence of category CE or 
DE will be removed  

SO3 

142 

 
Driver 

Policy measure 

Short description 

Link  to  a  specific 
objective 

PM9: Flexibility for the first issuance 
in  case  of 
licences 
of  driving 
restrictions related to languages  

Applicants  that  are  EU  nationals  shall  be  able  to  obtain  their  first  driving  licence  of 
category B in their country of citizenship in the event their state of normal residence does 
not  allow  interpreters  and  the  official  language  of  their  country  of  citizenship  is  not 
available for theoretical or practical test in their country of normal residence  

recognition 
PM10:  Mutual 
physical and mental assessment  

of 

Verifications  that the  standards on  physical  and  mental  fitness  to  drive  are  met will  be 
mutually recognised by the Member States. 

PM11:  New  optional  equivalence 
related 
limited 
to  vehicles  with 
maximum speed  

The holder of a B1 licence aged 21 years old or less will be authorised to drive a vehicle 
whose maximum mass is 2 500 kg and maximum speed is physically limited to 45 km/h 
on the territory of his or her issuing state if that later has decided to implement this optional 
equivalence 

PD4 
PD5 

PD5 

PM12: Rules on the removal of code 
70 

The code 70 will be removed from the licence when the driver has been holding an EU 
licence for at least 5 years and has not committed serious road traffic offenses.  
Driving licences will be issued without a code 70 in the event of an exchange of foreign 
licences as concerns former holders of an EU driving licence for the categories obtained 
after passing tests in the EU 

PM13:  New  optional  equivalence 
related to bus without passengers 

The holder of a driving licence of category C will be authorised to drive a bus without 
passengers on the territory of his or her issuing state if that later has decided to implement 
this optional equivalence.  

PM14:  Rules  on  the  exchange  of 
foreign driving licences.  

Rules will be introduced establishing a legal basis for the exchange of driving licences 
issued  by  a  third  country  whose  licensing  system  guarantees  a  level  of  road  safety 
equivalent to the one in the EU. The issued driving licences will not be marked with a code 
70. MS will be able to continue to establish new framework under the current rules for the 
exchange  of  driving  licences  with  countries  whose  level  of  road  safety  has  not  been 
assessed.  

143 

 
 
ANNEX 7: VEHICLE CATEGORIES 

This annex explains the various categories of vehicles specified by Article 4 of Directive 
2006/126/EC. These categories are marked on the driving licences and refer to the type of 
vehicles that a person can drive when he or she holds a driving licence of the corresponding 
category. 

Motorcycles, motor tricycles, light quadricycles and mopeds 

Category  Type of vehicles 

AM 

A1 

A2 

A 

Two-wheel vehicles or three-wheel vehicles with a maximum design speed of not 
more than 45 km/h, as defined in Article 1(2)(a) of Directive 2002/24/EC305 of the 
European Parliament and of the Council of 18 March 2002 relating to the type-
approval of two or three-wheel motor vehicles (excluding those with a maximum 
design speed under or equal to 25 km/h),  

light quadricycles as defined in Article 1(3)(a) of Directive 2002/24/EC 

motorcycles  with  a  cylinder  capacity  not  exceeding  125  cubic  centimetres,  of a 
power  not  exceeding  11  kW  and  with  a  power/weight  ratio  not  exceeding  0,1 
kW/kg,  

motor tricycles with a power not exceeding 15 kW,  

motorcycles of a power not exceeding 35 kW and with a power/weight ratio not 
exceeding 0,2 kW/kg and not derived from a vehicle of more than double its power,  

motorcycles  

motor tricycles with a power exceeding 15 kW 

Cars and vans 

Category  Type of vehicles 

B 

B1 

BE 

motor  vehicles  with  a  maximum  authorised  mass  not  exceeding  3  500  kg  and 
designed  and  constructed  for  the  carriage  of  no  more  than  eight  passengers  in 
addition  to  the  driver;  motor  vehicles  in  this  category  may  be  combined  with  a 
trailer having a maximum auth orised mass which does not exceed 750 kg. 

quadricycles, as defined in Article 1(3)(b) of Directive 2002/24/EC (optional) 

combination of vehicles consisting of a tractor vehicle in category B and a trailer 
or semi-trailer where the maximum authorised mass of the trailer or semi-trailer 
does not exceed 3 500 kg,  

305  Directive 2002/24/EC has been repealed by Regulation (EU) No 168/2013. 

144 

 
 
                                                 
Trucks 

Category  Type of vehicles 

C 

CE 

C1 

motor vehicles other than those in categories D1 or D, whose maximum authorised 
mass is over 3 500 kg and which are designed and constructed for the carriage of 
no  more  than  eight  passengers  in  addition  to  the  driver;  motor  vehicles  in  this 
category may be combined with a trailer having a maximum authorised mass which 
does not exceed 750 kg;  

combinations of vehicles where the tractor vehicle is in category C and its trailer 
or semi-trailer has a maximum authorised mass of over 750 kg,  

motor vehicles other than those in categories D1 or D, the maximum authorised 
mass of which exceeds 3 500 kg, but does not exceed 7 500 kg, and which are 
designed  and  constructed  for  the  carriage  of  no  more  than  eight  passengers  in 
addition  to  the  driver;  motor  vehicles  in  this  category  may  be  combined  with  a 
trailer having a maximum authorised mass not exceeding 750 kg;  

C1E 

combinations of vehicles where the tractor vehicle is in category C1 and its trailer 
or semi-trailer has a maximum authorised mass of over 750 kg provided that the 
authorised mass of the combination does not exceed 12 000 kg,  

combinations of vehicles where the tractor vehicle is in category B and its trailer 
or semi-trailer has an authorised mass of over 3 500 kg, provided that the authorised 
mass of the combination does not exceed 12 000 kg,  

Buses 

Category  Type of vehicles 

D 

DE 

D1 

motor  vehicles  designed  and  constructed  for  the  carriage  of  more  than  eight 
passengers in addition to the driver; motor vehicles which may be driven with a 
category D licence may be combined with a trailer having a maximum authorised 
mass which does not exceed 750 kg;  

combinations of vehicles where the tractor vehicle is in category D and its trailer 
has a maximum authorised mass of over 750 kg,  

motor  vehicles  designed  and  constructed  for  the  carriage  of  no  more  than  16 
passengers in addition to the driver and with a maximum length not exceeding 8 
m;  motor  vehicles  in  this  category  may  be  combined  with  a  trailer  having  a 
maximum authorised mass not exceeding 750 kg;  

D1E 

combinations of vehicles where the tractor vehicle is in category D1 and its trailer 
has a maximum authorised mass of over 750 kg,  

145 

 
 
ANNEX 8: MINIMUM AGES 

This annex explains the minimum ages specified by Article 4 of Directive 2006/126/EC. 
These ages are the minimum ages required to obtain a driving licence of a given category. 
Reference to flexibility indicates the possibility for a Member State to choose a different 
minimum age in an interval specified by the Directive.   

1. MINIMUM AGE FOR MOPEDS, MOTORCYCLES, TRICYCLES, QUADRICYCLES, CARS AND 
VANS (DIRECTIVE 2006/126/EC) 

Motorcycles, tricycles, light quadricycles and Mopeds 

AM 

A1 

A2  

A (tricycles) 

Baseline 

16 years 

16 years 

18 years 

21 years 

For category AM, a flexibility on the minimum age (down to 14 years or up to 18 years) 
may be applied. 

A 
(motorcycles) 

baseline 

Direct access 

24 years 

Graduated access 

20 years 
(after 2 years of 
A2 experience) 

For the graduated access, a flexibility on the minimum age may be applied. 

Flexibility 
#1 

Flexibility 
#1 

A1 

A2  

17 years 

18 years 

19 years 

20 years 

A 
(motorcycles) 

21 years 
(after 2 
years of A2 
experience) 

22 years 
(after 2 
years of A2 
experience) 

146 

 
 
 
 
 
 
 
 
Cars, heavy quadricycles and vans  

Baseline 

B1 

16 years 

B / BE 

18 years 

Flexibility* 

up to 18 years 
* Only within the territory of Member States applying the provision 

down to 17 years 

2. MINIMUM AGE FOR DRIVERS OF TRUCKS AND BUSES 

Trucks and buses without a professional qualification (Directive (EU) 2022/2561) 

C1 / C1E 

C / CE 

D1 / D1E 

D / DE 

18 years 

21 years 

21 years 

24 years 

Trucks and buses with a professional qualification (Directive (EU) 2022/2561) 

C / CE 

D / DE 

D / DE 
(accelerated qualification with 
restrictions) 

18 years 
(standard qualification) 

21 years 
(standard qualification) 
23 years 
(accelerated qualification) 
Minimum age for categories C1/C1E and D1/D1E are the same as above (18 and 21 years). 

21 years 
(service route < 50km) 

Optional flexibilities with a professional qualification (Directive (EU) 2022/2561) 

D1 / D1E 

D/DE 

D / DE 
(standard qualification 
with restrictions) 

20 years 
(standard qualification) 

18 years 
(standard qualification) 

18 years 
(without passengers) 
or  
(service route < 50km) 
Only within the territory of Member States applying the provision 

Standard qualification refers to a Certificate of Professional Competence as referred to in 
Article 6(1) of Directive (EU) 2022/2561. 

Accelerated qualification refers to a Certificate of Professional Competence as referred to 
in Article 6(2) of Directive (EU) 2022/2561. 

147 

 
 
 
 
 
 
 
 
ANNEX 9: LINKS BETWEEN MAIN CONCLUSIONS OF THE EX-POST 
EVALUATION AND THE IMPACT ASSESSMENT 

The  following  table  summarises  the  links  between  the  conclusions  of  the  ex-post 
evaluation and the impact assessment of the Driving Licences Directive. 

Main ex-post evaluation conclusions 

Impact Assessment  

Conclusions on relevance 

The  current  rules  on  driving  skills  and  knowledge  do  not 
sufficiently reflect new technological solutions, such as advanced 
driver assistance systems, semi-automated and automated driving, 
as  well  as  the  uptake  of  micro-mobility  solutions  and  low-  and 
zero-emissions vehicles with automatic gear transmission. 

Conclusions on effectiveness 

The effect of the Directive on road safety is considered as being 
positive but is assessed to be insufficient to meet the EU targets 
for 2030. In addition, there are still some provisions which, when 
implemented,  may  create  obstacles  to  the  free  movement  of 
persons. 

Conclusions on efficiency 

Standardised  validity  periods,  the  requirement  to  renew  driving 
licences and regular medical checks for professional drivers are 
likely  to  have  increased  both  the  administrative  burden  and  the 
costs for citizens. Some stakeholders also claim that the system of 
progressive access to category A licences has led to higher costs 
and burdens for applicants. 
The Union model driving licence and RESPER do not appear to 
have  led  to  higher  costs  for  citizens;  they  have  likely  helped 
reduce administrative burden. 
Digital solutions, including the mobile driving licences have not 
been sufficiently explored, and RESPER could be used more to 
reduce the administrative burden. 

Conclusions on coherence 

The  Directive  complements 
the  cross-border  enforcement 
Directive, but possible synergies in enforcement through a mutual 
recognition of driving disqualifications are not exploited.  
The  Directive  could  also  be  better  aligned  with  the  EU  type 
approval legislation for vehicles. 
With  the  digital  transformation  (already  started  with  the  use  of 
RESPER), focus on data protection and the GDPR is needed. 

Conclusions on EU Added Value 

impact 

assessment 

The 
further 
develops  the  specific  objectives  but 
the general objective (improving road 
safety  and 
free 
movement of people) remains valid. 

facilitating 

the 

Policy measures are defined to support 
the EU framework with new rules on 
training  and  probation  periods,  the 
driving 
mutual 
disqualifications  and  guidelines  for 
establishing the normal residence. 

recognition 

of 

Policy measures are defined to enable 
the simplification and reduction of the 
administrative burden, in particular in 
relation to digital transformation. 
Furthermore, 
recognition  of 
the 
mobile driving licences is expected to 
improve  efficiency,  including  when 
implementing 
administrative 
procedures. 

The impact assessment identifies areas 
where 
is 
terms  of 
required, 
vehicles’ definition and recognition of 
disqualifications. 

improving 
including 

coherence 
in 

Without the Directive, EU countries would likely have cooperated 
through  bilateral  agreements  and  through  other  means,  which 
would  most  likely  have  resulted  in  more  complex  licensing 
systems and a  higher  administrative burden. In  this respect, the 
main  benefit  of  the  Directive  is  the  increased  harmonisation  of 
driving licence rules across the EU.  
However, EU action is still needed on some specific topics. 

EU  action  continues  to  be  needed  to 
deliver on the policy objectives of the 
DL Directive, for instance by enabling 
the  mutual  recognition  of  mobile 
driving licences, by improving the use 
of  RESPER  and  by  clarifying  the 
normal residence concept. 

148 

 
 
 
 
 
 
 
ANNEX 10: EFFECTS ON ROAD SAFETY – QUALITATIVE 
ASSESSMENT 

This  annex  summarises  hereafter  the  qualitative  assessment  of  the  expected  effects  of 
policy measures and options on road safety. This complements the quantitative analysis 
performed for measures with more significant impact, detailed in Annex 4.  

Positive impact 

In terms of positive impact, all policy options will contain measures on updated standards 
on skills and knowledge which applicants will have to meet for the first issuance of the 
driving licence (PMc1). Literature has shown that hazard perception test and training result 
in drivers avoiding 16% more hazards306 and in a reduction around 10% of “non-low-speed 
public road crashes”307. The UK has introduced a hazard perception test which has been 
considered  as  potentially  saving  hundreds  of  lives  every  year308.  In  addition,  the 
improvement of RESPER (PMc4), the introduction of a possible QR code (PMc10) and 
the  introduction  of  the  EU  digital  driving  licence  (PMc9)  should  allow  to  verify  more 
efficiently the validity of a driving licence during a roadside check or an administrative 
procedure. It will result in a limited positive impact on road safety by improving the means 
to  fight  against  fraud  and  consequently  by  reducing  impunity.  The  rules  on  the  use  of 
technologies to mitigate medical unfitness (PMc6) should allow to maintain the driving 
rights for persons unfit to drive (for example, with an alcohol interlock). Consequently, it 
will  provide  a  secure  environment  to  these  drivers  that  could  have  continued  to  drive 
without  a  driving  licence  with  the  current  rules.  The  establishment  of  an  information 
platform  expert  group  on  medical  fitness  to  drive  (PMc7)  should  enable  more  share  of 
knowledge, lessons learnt and best practices on the assessment of the physical and mental 
fitness to drive between Member States authorities. It is expected to progressively improve 
the national systems in place. All policy options will also provide the clarification of the 
concept of normal residence (PMc8) which should help if a person may claim two or more 
normal residences. It will allow to identify drivers taking benefit of their personal situation 
to  avoid  the  consequence  of  offenses.  The  resulting  impact  on  impunity  will  have  an 
indirect small effect on road safety.  

The positive impact on road safety is however expected to be higher in PO-B and PO-C, 
given that they both introduce another set of measures with additional positive impact: the 
introduction  of  rules  on  training  and  probation  period,  with  a  probation  period  of  a 
minimum of 2 years for novice drivers, and recommendation on lifelong learning (PM1). 
Accompanied driving after passing the driving test at 17 has shown a reduction of 22% of 
accidents in Germany309 per kilometre driven by these drivers. The mutual recognition of 
driving disqualifications for offenses such as excessive speed driving and driving under 
the  influence  of  alcohol  (PM4)  should  also  contribute  to  road  safety,  with  additional 
expected effects resulting from rules on penalty points and rehabilitation (PM 5) in case of 
PO-C. In the public consultation, the mutual recognition of driving disqualifications has 
been recognised to have a positive impact on road safety regarding speeding (5,143 out of 

306  Vidotto,  G.,  Bastianelli,  A.,  Spoto,  A.,  &  Sergeys,  F.  (2011).  Enhancing  hazard  avoidance  in  teen novice  riders. 

Accident Analysis and Prevention, 43(1), 247–252 

307  https://impact.ref.ac.uk/casestudies/CaseStudy.aspx?Id=37241  
308  https://www.gov.uk/government/news/hazard-perception-test-wins-road-safety-award  
309  BASt - Berichte der BASt - Summative Evaluation of "Accompanied Driving from Age 17" 

149 

 
                                                 
7,532 or 68% respondents) and driving under the influence (6,224 out of 7,532 or 82% 
respondents) 

Both PO-B and PO-C would also benefit from rules on medical screening and assessment 
(PM  6  and  PM  7  respectively),  bringing  additional  positive  impact  for  the  road  safety. 
Minor but still positive impact for PO-C compared to other two options would have the 
introduction  of  micro  mobility  vehicles  in  the  scope  of  category  AM  (PM2)  requiring 
driving licence, which should reduce the number of fatalities involving such vehicles for 
speeds between 25 km/h and 45 km/h. 

Neutral impact expected 

The policy options also include measures which are not expected to have a negative impact 
on road safety, even if they may be perceived as potentially deteriorating the road safety. 
Such  measure,  included  in  all  policy  options,  are  the  updated  rules  for  vehicles  with 
automatic  gear  transmission  (PMc2).  The  removal  of  restrictions  (code  78)  is  currently 
obtained by doing a full test on a vehicle with manual transmission. The new rules will 
allow the removal of this code following a certified training or a practical test, focusing on 
the difference between manual and automatic transmission and providing the same level 
of assurance of the capability of the driver to control a vehicle with a manual transmission 
as with the current rule. A similar rule is in place in Germany and has not shown an increase 
of accidents involving drivers previously subject to the code 78 restrictions. The update of 
the  standards  on  physical  and  mental  fitness  (PMc5)  is  also  expected  to  have  a  neutral 
impact on road safety. It envisages the reduction of the frequency of medical checks for 
drivers suffering diabetes mellitus which reflects the evolution of the health care regarding 
this  medical  issue  since  1996.  The  mutual  recognition  of  optional  equivalence  and  the 
introduction of a new equivalence related to small buses and trailer (PMc12) should also 
have a negligible impact on road safety. Both measures are expected to cover a very limited 
number of drivers. The new equivalence already exists for bigger buses from the second 
Directive  (applicable  from  1994)  which  also  includes  the  optional  equivalences  to  be 
mutually  recognised.  The  data  available  on  road  fatalities  do  not  indicate  any  specific 
negative pattern regarding these rules.  

The introduction of a new category for tractors and the change to the definition of category 
D1 (PM3): regarding small buses, reflect an evolution of the market offer. The dimension 
of  these  buses  will  remain  unchanged  (below  8  meters).  Regarding  tractors,  while 
differences  can  be  noticed  in  the  national  licensing  systems,  their  use  in  a  professional 
context in rural areas is not expected to be a source of increased number of accidents.  

Additional measures brought about in PO-B and PO-C are also expected to have a neutral 
impact on road safety. This applies to the removal of the staging requirement (need to have 
the licence of category C or D to obtain a licence of category CE or DE under PM8) where 
the standards to be met at the driving test for categories CE or DE include the ones required 
for category C or D. In addition, the professional qualification (Directive (EU) 2022/2561) 
foresees a verification of the skills and knowledge of the driver regarding driving ability 
and  road  safety.  The  introduction  of  an  optional  equivalence  allowing  to  drive  a  bus 
without passengers with a licence of category C (PM3) concerns extremely limited routes 
and the standards to be met at the driving tests for a bus are the same as the ones for a truck 
except for what concerns passengers. 

150 

 
Being included only in PO-C, the introduction of rules on the exchange of foreign driving 
licences (PM14) is not expected to have negative impacts, since the rules will only concern 
driving licences issued by third countries whose licensing system is similar to the EU one 
regarding road safety. Also included in PO-C, the rules on the removal of code 70 (PM12) 
require that the former holder of a foreign driving licence has a positive track record in 
term of road safety. 

Marginal negative impact expected  

All  policy  options  contain  two  measures  having  a  potentially  negative  impact  on  road 
safety, while bringing positive impacts for the other objectives of the initiative. It has not 
been possible to quantify them. The increase of the maximum mass for category B to 4.25t 
(PMc3) is expected to have a limited negative effect on road safety. While the increase of 
the mass is likely to result in an increase of fatalities and serious injuries for vulnerable 
road users, the effect will be partially mitigated by the scope of application of the measure 
limited to electric vehicles. On the other hand, the vehicles concerned will be the recent 
ones and will benefit from advanced technologies regarding road safety.  

The harmonisation of the administrative validity to 15 years (PMc11) is expected to have 
a limited negative effect on road safety. It will reduce the frequency of medical check for 
MS which now apply an administrative validity of 10 years and request a medical check 
or screening at renewal310.  

While certain of the measures above may concerns the same driver, we have not been able 
to identify a negative impact on road safety resulting from the combined effects of each of 
the measures.

310  AT, BE, CY, EL, ES, FI, HU, IE, IT, LV, NL, PL, PT, RO and SE (78% of group 1 licences) 

151 

 
                                                 
ANNEX 11: EFFECTIVENESS OF THE POLICY OPTIONS 

The following table summarises the expected effectiveness of each policy option, complementing the description in section 7.1. 

152 

 
Key expected impacts  

 

Strongly negative 

 

Negative 

Specific objective 1: improve driving skills, knowledge and experience 
and reduce and punish dangerous behaviour 

Standards on skills, knowledge, training and probation periods to be met for 
the first issuance of a driving licence are harmonised 

O 

No or negligible impact 

PO-A 

 

Positive 

PO-B 

 

Strongly positive 

PO-C 

Positive  impact  on  road  safety,  due  to 
upgraded skills resulting in 106 avoided 
fatalities and serious injuries in 2030 and 
84  in  2050.  Cumulatively,  over  2025-
2050,  avoided  fatalities  and  serious 
injuries amount to 2,388 relative to the 
baseline. 

Strong positive impact on road safety, 
due to: 

Strong positive impact on road safety, 
due to: 

-  upgraded  skills,  resulting  in  106 
avoided  fatalities  and  serious  injuries 
in 2030 and 84 in 2050. Cumulatively, 
over 2025-2050, avoided fatalities and 
serious injuries amount to 2,388. 

-  upgraded  skills,  resulting  in  106 
avoided fatalities and serious injuries in 
2030  and  84  in  2050.  Cumulatively, 
over 2025-2050, avoided fatalities and 
serious injuries amount to 2,388. 

-  probation  periods  and 
training 
implemented  across  the  EU,  helping 
avoid  338 
fatalities  and  serious 
injuries  in  2030  and  306  in  2050. 
Cumulatively, 
2025-2050, 
avoided  fatalities  and  serious  injuries 
the 
to  8,360  relative 
amount 
baseline. 

over 

to 

-  probation  periods  and 
training 
implemented  across  the  EU,  helping 
avoid 338 fatalities and serious injuries 
in 2030 and 306 in 2050. Cumulatively, 
over 2025-2050, avoided fatalities and 
serious 
to  8,360 
relative to the baseline. 

injuries  amount 

153 

 
 
 
 
 
 
 
 
Strong  positive  impact  on  road  safety 
due  to  the  mutual  recognition  of 
driving  disqualifications  for  severe 
road  traffic  offences  combined  with 
rules  on  penalty  points,  which  will 
result  in  95  less  fatalities  and  serious 
injuries  in  2030  and  74  in  2050. 
Cumulatively, 
2025-2050, 
avoided  fatalities  and  serious  injuries 
the 
to  2,097,  relative 
amount 
baseline. 

over 

to 

Additional  albeit 
limited  positive 
impact  on  road  safety  due  to  the 
introduction  of  the  EU  digital  driving 
licence,  which  should  allow  to  verify 
more  efficiently  the  validity  of  a 
driving licence during a roadside check 
or an administrative procedure thereby 
improving  the  means  to  fight  against 
fraud  and  consequently 
reducing 
impunity. 

Dangerous behaviour abroad is more coherently punished 

Positive  impact  is  expected  due  to 
improvements  to  RESPER  to  improve 
data quality and specifying the response 
delays  to  requests  and  ensure  a  better 
fight  against 
fraud  and  dangerous 
behaviour. This will support cooperation 
between  issuing  authorities  which  will 
also benefit from access to the system to 
check  the  validity  of  a  digital  driving 
licence. 

Strong positive impact on road safety 
due  to  the  mutual  recognition  of 
driving  disqualifications  for  severe 
road traffic offences, which will result 
in 53 less fatalities and serious injuries 
in 2030 and 32 in 2050. Cumulatively, 
over 2025-2050, avoided fatalities and 
serious injuries amount to 947, relative 
to the baseline. 

Additional albeit limited positive impact 
on road safety due to the introduction of 
the  EU  digital  driving  licence,  which 
should  allow  to  verify  more  efficiently 
the validity of a driving licence during a 
roadside  check  or  an  administrative 
procedure thereby improving the means 
to  fight  against  fraud  and  consequently 
reducing impunity. 

Additional  albeit 
limited  positive 
impact  on  road  safety  due  to  the 
introduction of the EU digital driving 
licence,  which  should  allow  to  verify 
more  efficiently  the  validity  of  a 
driving  licence  during  a  roadside 
check  or  an  administrative  procedure 
thereby improving the  means to fight 
consequently 
and 
against 
reducing impunity. 

fraud 

154 

 
 
 
 
 
 
 
 
 
 
Strongly positive impact on the number 
of  lives  saved  due  to  the  advanced 
medical  screening,  which  will  reduce 
fatalities and serious injuries by 369 in 
2030  and  306  in  2050.  Cumulatively, 
over 2025-2050, avoided fatalities and 
to  8,428, 
serious 
relative to the baseline. 

injuries  amount 

In addition, positive impact of updated 
standards  on  skills  and  knowledge 
risk 
as  perception 
(such 
awareness, 
new 
adaptation 
technologies),  which  applicants  will 
have to meet for the first issuance of the 
driving licence 

tests, 
to 

Specific  objective  2:  ensure  adequate  physical  and  mental  fitness  of 
drivers across the EU 

Drivers are regularly  medically screened, depending on their health status 
and age  

Positive impact of updated standards on 
skills and knowledge (such as perception 
tests, risk awareness, adaptation to new 
technologies),  which  applicants  will 
have to meet for the first issuance of the 
driving licence 

impact  on 

Strongly  positive 
the 
number  of  lives  saved  due  to  the 
simple  medical  screening,  which  will 
reduce fatalities and serious injuries by 
in  2050. 
116 
Cumulatively, 
2025-2050, 
avoided  fatalities  and  serious  injuries 
amount 
the 
to  2,352,  relative 
baseline. 

in  2030  and  94 

over 

to 

In addition, positive impact of updated 
standards  on  skills  and  knowledge 
risk 
as  perception 
(such 
awareness, 
new 
adaptation 
technologies),  which  applicants  will 
have  to  meet  for  the  first  issuance  of 
the driving licence 

tests, 
to 

155 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Specific  objective  3:  Remove  inadequate  or  unnecessary  barriers 
affecting applicants and holders of driving licences 

Mobile driving licence recognised across the EU  

Removal  of  cases  where  normal  residence  is  an  obstacle  to  exercise  of 
maintain driving rights 

Strong  positive  impact  on  removing 
barriers to the free movement of people 
due to the introduction and use of mobile 
driving licences, which will be mutually 
recognised  across  the  EU.  This  will 
bring  hassle  cost  savings  of  EUR 
1,697.2  million  for  citizens  and  EUR 
587 million for businesses, expressed as 
present value over the 2025-2050 period 
(relative to the baseline). 

Positive  impact  on  fundamental  rights 
and free movement of people is expected 
due to the clarification of the concept of 
normal  residence,  even  if  the  expected 
impact  should  be  small  due  to  the  low 
number of cases. But the consequences 
for  individuals  can  be  significant  and 
can 
free 
movement  of  these  road  users.  It  is 
expected  to  have  a  positive  impacts  to 
the  costs 
to  handling  of 
complaints from citizens and in extreme 
cases,  court  rulings.  They  are  also 
expected  to  result  in  a  reduction  of  the 
hassle costs for citizens. 

importantly 

related 

impair 

the 

Strong  positive  impact  on  removing 
barriers  to  the  free  movement  of 
people due to the introduction and use 
of mobile driving licences, which will 
be mutually recognised across the EU. 
This will bring hassle cost savings of 
EUR  1,697.2  million  for  citizens  and 
EUR  587  million  for  businesses, 
expressed  as  present  value  over  the 
2025-2050  period  (relative  to  the 
baseline). 

Positive impact on fundamental rights 
and  free  movement  of  people  is 
expected due to the clarification of the 
concept  of  normal  residence,  even  if 
the  expected  impact  should  be  small 
due  to  the  low  number  of  cases.  But 
the  consequences  for  individuals  can 
be  significant  and  can  importantly 
impair  the  free  movement  of  these 
road  users.  It  is  expected  to  have  a 
positive impacts to the costs related to 
handling  of  complaints  from  citizens 
and  in  extreme  cases,  court  rulings. 
They  are  also  expected  to  result  in  a 
reduction  of  the  hassle  costs  for 
citizens.  

Strong  positive  impact  on  removing 
barriers to the free movement of people 
due  to  the  introduction  and  use  of 
mobile driving licences, which will be 
mutually  recognised  across  the  EU. 
This  will  bring  hassle  cost  savings  of 
EUR  1,697.2  million  for  citizens  and 
EUR  587  million  for  businesses, 
expressed  as  present  value  over  the 
2025-2050  period  (relative 
the 
baseline). 

to 

Positive impact on fundamental  rights 
and  free  movement  of  people 
is 
expected due to the clarification of the 
concept  of  normal  residence,  even  if 
the  expected  impact  should  be  small 
due to the low number of cases. But the 
consequences  for  individuals  can  be 
significant and can importantly impair 
the free movement of these road users. 
It is expected to have a positive impacts 
to  the  costs  related  to  handling  of 
complaints 
in 
extreme cases, court rulings. They are 
also expected to result in a reduction of 
the hassle costs for citizens.  

from  citizens  and 

Positive  impacts  for  the  applicants  in 
cases  of  first  issuance  of  driving 
licence  category  B,  due  to  reduced 
barriers 
language 
requirements for driving licence tests. 
Some reduction in hassle costs for the 
citizens concerned is expected. 

related 

to 

Positive  impacts  for  the  applicants  in 
cases of first issuance of driving licence 
category  B,  due  to  reduced  barriers 
related  to  language  requirements  for 
driving licence tests. Some reduction in 
hassle costs for the citizens concerned is 
expected. 

156 

Positive  impacts  for  the  applicants  in 
cases  of  first  issuance  of  driving 
licence  category  B,  due  to  reduced 
barriers 
language 
requirements  for  driving  licence  tests. 
Some reduction in hassle costs for the 
citizens concerned is expected. 

related 

to