COMMISSION STAFF WORKING DOCUMENT Social rules in road transport Accompanying the document REPORT FROM THE COMMISSION TO THE EUROPEAN PARLIAMENT AND THE COUNCIL on the implementation in 2019-2020 of Regulation (EC) No 561/2006 on the harmonisation of certain social legislation relating to road transport and of Directive 2002/15/EC on the organisation of the working time of persons performing mobile road transport activities (31st report from the Commission on the implementation of the social legislation relating to road transport), and on controls preformed under Council Directive 96/53/EC laying down for heavy-duty vehicles the maximum authorized dimensions and the maximum authorized weights
Date: 2023-04-04
Institutions: Directorate-General for Mobility and Transport, European Commission
Subjects: EU Member State, application of EU law, arrangement of working time, drivers, driving period, rest period, road safety, road transport, social legislation, transport statistics

EN 

  EN 

   EUROPEAN COMMISSION  Brussels, 4.4.2023  SWD(2023) 74 final  COMMISSION STAFF WORKING DOCUMENT Social rules in road transport      Accompanying the document REPORT FROM THE COMMISSION TO THE EUROPEAN PARLIAMENT AND THE COUNCIL  on the implementation in 2019-2020 of Regulation (EC) No 561/2006 on the harmonisation of certain social legislation relating to road transport and of Directive 2002/15/EC on the organisation of the working time of persons performing mobile road transport activities (31st report from the Commission on the implementation of the social legislation relating to road transport), and on controls preformed under Council Directive 96/53/EC laying down for heavy-duty vehicles the maximum authorized dimensions and the maximum authorized weights                                           {COM(2023) 183 final}  
 
 
1. Social legislation in road transport – objectives and key provisions 

The  EU  social  rules  in  road  transport  are  established  by  four  interrelated  acts:  Regulation 
(EC)  No  561/2006,  which  establishes  rules  on  driving  times,  breaks  and  rest  periods  for 
professional drivers, Directive 2002/15/EC, which sets out complementary provisions on the 
organisation  of  the  working  time  of  persons  performing  mobile  road  transport  activities, 
Regulation  (EU)  No  165/2014  on  recording  equipment  in  road  transport,  and  Directive 
2006/22/EC, which determines minimum requirements for enforcement of these rules.  

Regulation  (EC)  No  561/2006,  also  known  as  the  Driving  Time  Regulation,  applies  to 
employed  and  self-employed  drivers  engaged  in  the  carriage  by  road  of  goods  where  the 
maximum permissible mass of the vehicle exceeds 3.5 tonnes1 and of passengers by vehicles 
carrying more than nine persons including the driver. The maximum weekly driving time of a 
driver should not exceed 56 hours (provided that no more than 90 hours are driven in any two 
consecutive weeks). The total daily driving time should not exceed 9 hours, although twice a 
week it can be extended to 10 hours. Breaks should last for at least 45 minutes (which may be 
separated into a break of 15 minutes followed by 30 minutes) and should be taken not later 
than after 4.5 hours of driving. The daily rest period is determined at the level of minimum 11 
hours, which can be reduced three times a week to 9 hours.  

Directive 2002/15/EC, also known as the “Road Transport Working Time Directive”, applies 
to mobile workers such as drivers, crew and other travelling staff, both with the employment 
or  self-employment  status.  The  Directive  complements  Regulation  (EC)  No  561/2006  by 
putting in place limitations on the maximum weekly and maximum average weekly working 
time of mobile workers in the road transport sector as well as adequate breaks and night work 
provisions. 

Directive  2002/15/EC  defines  working  time  as  time  devoted  to  all  road  transport  activities, 
including  driving,  loading  and  unloading,  assisting  passengers  boarding  and  disembarking 
from the vehicle, cleaning and technical maintenance and all other work intended to ensure 
the safety of transport operation. Specific time limits are set out in relation to weekly working 
time (excluding breaks  and periods of availability)  which amounts to  maximum  48 hours a 
week, which may be extended to 60 hours, provided that over four months, an average of 48 
hours  a  week  is  maintained.  Moreover,  a  limitation  to  10  hours  on  daily  working  time  is 
introduced in case of night work. Each mobile worker is obliged to take a break after working 
consecutively for 6 hours, which should be at least 30 minutes, if working hours range from 
six to nine hours and at least 45 minutes, if working time equals to more than nine hours.  

Regulation  (EU)  No  165/2014  on  tachographs  in  road  transport  sets  out  obligations  and 
requirements  in  relation  to  the  construction,  installation,  use,  testing  and  control  of 
tachographs  used  in  road  transport,  in  order  to  verify  compliance  with  the  provisions  of 
Regulation  (EC)  No  561/2006  and  Directive  2002/15/EC2.  It  also  aims  at  reducing  the 

1 As provided by Article 2 of Regulation (CE) No 561/2006, amended by Regulation (EU) 2020/1054, the rules 
set out in Regulation (EC) 561/2006 will be extended as of 1 July 2026 to drivers of vehicles which exceed 2,5 
tonnes in international transport operations of goods.  
2 Pursuant to Article 1(1) of Regulation (EU) No 165/2014, as amended by Regualtion (EU) 2020/1054, from 20 
August 2020, tachographs may also be used to verify compliance with other Union legislation, for example with 
Regulations (EC) No 1071/2009, (EC) No 1072/2009 and (EC) No 1073/2009.  

1 

 
                                                           
 
administrative burden and making fraud to the tachograph more difficult. A smart tachograph 
has to be fitted in vehicles registered for the first time as of 15 June 20193. A second version 
of  the  smart  tachograph,  which  is  currently  in  development,  will  have  advanced 
communication features including with control devices of roadside enforcers, as well as other 
features  including  the  automatic  recording  of  border  crossings  and  the  recording  of  the 
position of the vehicle during loading and/or unloading operations. These capabilities broaden 
the  areas  of  enforcement  where  the  tachograph  is  applied,  extending  it  to,  for  instance,  the 
control of cabotage operations or the application of the rules on the posting of drivers.  

Directive  2006/22/EC,  also  called  the  "Enforcement  Directive",  lays  down  rules  to  verify 
compliance  and  ensure  application  of  rules  for  driving  time  and  rest  periods  established  by 
Regulation  (EC) No 561/2006  and Regulation  (EU) No 165/20144. The Directive promotes 
harmonised  enforcement  of  the  social  rules  in  road  transport  by  means  of  minimum 
requirements for the uniform and effective checks to be carried out by Member States. The 
minimum threshold of checks of the total number of days worked by drivers falling under the 
scope of Regulation (EC) No 561/2006 and Regulation (EU) No 165/2014 is set at 3 % from 
2010.  In  addition,  the  total  number  of  working  days  checked  should  be  carried  out  in  a 
proportional manner for checks at the roadside and at the premises of transport undertakings 
–  at  least  30  %  and  50  %  respectively.  An  obligation  of  minimum  six  concerted  roadside 
checks per year undertaken by two or more enforcement authorities was introduced in order 
to encourage cooperation between Member States.  

At the time of writing this report, Regulation (EC) No 561/2006, Regulation (EU) 165/2014 
and  Directive  2006/22/EC  were  amended  by  Mobility  Package  I5,  which  also  introduced 
specific rules on posting of drivers in the road transport sector6. New working times and rest 
periods  rules  started  applying  from  20  August  2020.  Taking  into  account  the  date  of 
application  of  the  new  provisions,  the  information  on  their  implementation  is  only  partly 
provided in the current report.  

This  Staff  Working  Document  is  accompanying  the  Report  and  provides  more  national 
figures and details as well as updates on other relevant aspects in the field. 

2. Checks 

In  2020,  the  whole  Europe  was  affected  by  Covid-19  crisis.  As  a  result,  no  inspections  of 
road  transport  were  carried  out  in  the  majority  of  the  EU  Member  States  for  a  period  of  4 

3 This applies to the first version of smart tachographs, while the second version of smart tachographs will have 
to be fitted in all newly registered vehicles as of 21 August 2023.  
4  Pursuant  to  Article  6  of  Directive  2006/22/EC,  as  amdend  by  Directive  (EU)  2020/1057,  from  2  February 
2022,  the  scope  of  the  Enforcement  Directive  also  covers  checking  compliance  with  some  provisions  of 
Directive 2002/15/EC.    
5  Regulation  (EU)  2020/1054  of  the  European  Parliament  and  of  the  Council  of  15  July  2020  amending 
Regulation (EC) No 561/2006 as regards minimum requirements on maximum daily and weekly driving times, 
minimum breaks and daily and weekly rest periods and Regulation (EU) No 165/2014 as regards positioning by 
means of tachographs (OJ L 249, 31.7.2020, p. 1–16) and Directive (EU) 2020/1057 of the European Parliament 
and of the Council of 15 July 2020 laying down specific rules with respect to Directive 96/71/EC and Directive 
2014/67/EU  for  posting  drivers  in  the  road  transport  sector  and  amending  Directive  2006/22/EC  as  regards 
enforcement requirements and Regulation (EU) No 1024/2012 (OJ L 249, 31.7.2020, p. 49–65). 
6  Directive  (EU)  2020/1057  of  the  European  Parliament  and  of  the  Council  of  15  July  2020  laying  down 
specific  rules  with  respect  to  Directive  96/71/EC  and  Directive  2014/67/EU  for  posting  drivers  in  the  road 
transport sector and amending Directive 2006/22/EC as regards enforcement requirements and Regulation (EU) 
No 1024/2012 (OJ L 249, 31.7.2020, p. 49–65). 

2 

 
                                                           
months  from  March  2020.  Following  that  period,  inspections  slowly  restarted,  but  with  the 
necessary  restrictions  and  precautions,  which  resulted  in  fewer  inspections  carried  out  than 
foreseen. 

The  total  number  of  working  days  checked  in  the  EU  decreased  by  8%  in  2019-2020 
compared to the period of 2017-2018. This is a continuous decreasing trend since 2011-2012, 
however the reductions in previous years were not so significant that in 2019-2020 (e.g. -5% 
in  the  previous  reporting  period).  Despite  this  decrease,  overall,  the  majority  of  Member 
States  performed  significantly  more  working  days  checks  than  required.  Seven  Member 
States performed significantly more checks than the 3% threshold: Romania (15,9%), Latvia 
(9.0%), Austria (8%), France (7.1%), Germany (6,9%) Portugal (6.3%) and Bulgaria (6.2%). 
These  are  the  same  Member  States  as  in  the  last  reporting  period.  Among  these  seven 
Member States only Romania increased the number of working days checked from 9.3% to 
15,9%, while other countries experienced decrease of this number.   

Six  Member  States  did  not  meet  the  minimum  threshold  of  3%,  namely  Greece  (2.4%), 
Hungary  (2.3%),  Ireland  (0.5%),  Luxembourg  (2.9%),  the  Netherlands  (1.5%)  and  Malta 
(0.2%).  This  is  the  same  number  of  countries  as  in  the  previous  reporting  period.  Great 
decreases in the number of working days checked were observed in Malta (-901%, i.e. from 
6,8% to 0.2%) and Bulgaria (-59%, i.e. from 9.6% to 6.2%). A great increase in the number 
of working days checked observed in Finland (from 1.4% to 4.7%) may be explained by the 
fact  that  Finland  reported  for  the  current  reporting  period  data  from  all  sources,  including 
data  from  the  national  police,  customs  and  occupational  health  &  safety  authorities,  which 
was not the case in the previous report.     

Hungary reported a significant increase in the number of vehicles subject to Regulation (EC) 
No  561/2006  with  more  than  two  times  as  many  vehicles  compared  to  the  last  reporting 
period (from 107.707 to 223.474).  

As  in  the  previous  reporting  period,  the  Netherlands  applied  "monitoring  based  on  trust", 
where  a  number  of  road  transport  undertakings  have  concluded  an  enforcement  agreement 
with  the  Environment  &  Transport  Inspectorate.  The  agreement  covered  over  1.4  million 
days worked by drivers during 2019-2020 in addition to the 885,196 working days checked 
by  the  Netherlands.  By  adding  these  figures  together,  the  Netherlands  meet  the  minimum 
threshold. The continuous development and expansion of the risk analysis enabled the Dutch 
inspectorates  to  focus  its  efforts  on  those  road  transport  undertakings  whose  level  of 
compliance was poor. This current monitoring system ends in 2022. As of that date the right 
technology will enable to monitor and investigate more drivers digitally. 

Directive  2006/22/EC  also  requires  that  at  least  50%  of  the  total  number  of  working  days 
checked should be done through checks at the premises of undertakings and at least 30% at 
the  roadside.  However,  looking  at  the  number  of  Member  States,  which  have  met  the 
threshold,  only  the  following  six  Member  States  have  the  required  balanced  share  between 
working  days  checked  at  the  premises  and  at  the  roadside:  Bulgaria  (53%  of  working  days 
checked at the premises), Cyprus (67%), Estonia (63%), Latvia (59%), Lithuania (63%), and 
Slovakia (63%). Bulgaria, Cyprus, Estonia, Latvia and Slovakia also met the ratio in the last 

3 

 
reporting period7. Yet, this is a decrease of two Member States compared to the last reporting 
period.  

The  ratio  of  working  days  checked  at  the  premises  with  the  EU-average  raised  to  40%  in 
2019-2020, which is the increasing trend compared to 27% in 2017-2018, 26% in 2015-2016, 
23% in 2013-2014 and 18% in 2009-2010. The most significant improvements were reported 
by  Cyprus  (from  59%  to  67%)  and  Slovakia  (from  57%  to  63%).  Romania  also  increased 
significantly  the  ratio  of  working  days  checked  at  the  premises  from  17%  in  2017-2018  to 
49% in the current reporting period, even though it still does not meet the minimum control 
targets at the roadside and at the premises.   

Greece  and  Ireland  are  the  only  Member  States,  which  have  not  met  the  threshold  for 
roadside  checks.  In  Ireland,  the  reason  seems  to  be  that  only  few  non-Irish,  except  British 
registered vehicles, are circulating on the Irish roads.  

3.  Checks  compared  to  the  number  of  enforcement  officers  and  equipment  to  analyse 
tachographs 

Based  on  the  number  of  enforcement  officers  reported  by  Member  States,  the  number  of 
control  officers  involved  in  checks  has  decreased  from  61,558  officers  in  2017-2018  to 
54,6798 in 2019-2020. The total number of enforcement officers trained to analyse the digital 
tachograph has continued to slightly decrease from 21,786 officers in 2017-2018 to 20,058 in 
2019-2020.  However,  the  units  of  equipment  provided  to  control  officers  to  analyse  the 
tachograph increased from 9,677 in 2017-2018 to 13,067 in 2019-2020. 

Table 1: Overview of national enforcement capacity in 2019-2020 per Member State 

MS 

AT 
BE 
BG 
HR 
CY 
CZ 
DK 
EE 
FI 
FR 
DE 
EL 
HU 
IE9 
IT10 

Control officers 
involved in checks 

Control officers 
trained to analyse the 
digital tachograph 

1100 
3833 
273 
244 
134 
1577 
8 
33 
426 
5500 
15646 
3069 
450 
18 
- 

1100 
3662 
273 
36 
8 
785 
8 
35 
360 
5500 
2822 
428 
400 
18 
- 

Units of equipment 
provided to control 
officers to analyse the 
tachograph 
275 
3518 
380 
36 
12 
410 
8 
19 
80 
3500 
2348 
130 
300 
18 
- 

7 Bulgaria, Cyprus, Denmark, Estonia, Latvia, Luxembourg, Malta, and Slovakia met the ratio in 2017-2018. 
8 This does not include data from Italy, who did not report on this subject. 
9 Ireland explained that these figures do not include members of the police force and solely refers to staff from 
the Road Safety Authority. 
10 Italy did not provide data.  

4 

 
                                                           
LV 
LT 
LU 
MT 
NL 
PL11 
PT 
RO 
SK 
SI 
ES 
SE 
TOTAL 

28 
200 
22 
1 
200 
1164 
19403 
315 
31 
74 
498 
432 
54679 

28 
300 
22 
1 
300 
1060 
1685 
315 
32 
74 
386 
420 
20058 

28 
65 
10 
1 
65 
256 
427 
315 
32 
40 
445 
349 
13067 

4. Roadside checks 

The  total  number  of  working  days  checked  at  the  roadside  was  74,581,610,  which  is  a 
decrease  compared  to  92,000,3912  working  days  checked  at  the  roadside  in  the  previous 
reporting  period.  In  general,  31%  of  vehicles  checked  at  the  roadside  are  from  another  EU 
country, which is a slight decrease since 2017-2018 (33%). However, in some Member States 
the  percentage  of  vehicles  from  another  EU  country  constitutes  more  than  half:  namely 
Austria  (65%),  Belgium  (53%),  France  (60%),  Luxembourg  (69%),  Malta  (63%),  and  the 
Netherlands  (57%).  These  are  the  same  Member  States  as  named  in  the  2017-2018  report 
except from Malta (increase from 45% to 63%) and Denmark (decrease from 51% to 36%). 
The geographic location and volume of transit operations may in certain Member States play 
a factor. Member States whose share of checking vehicles registered in a third country was 
the largest are Croatia (25%), Poland (22%), and Slovenia (26%)13. A complete overview per 
Member State can be found in Table 2 below. Austria explained that it is very much a transit 
country,  therefore,  the  proportion  of  working  days  checked  by  non-nationals  and  third 
countries is also higher than the proportion of own nationals, roadside checks being carried 
out without discrimination.  

Table 2: Share of checked vehicles at the roadside by country of registration 

MS 

AT 
BE 
BG 
HR 
CY 
CZ 
DK 
EE 
FI 

Nationals 

32% 
40% 
79% 
65% 
100% 
53% 
63% 
82% 
81% 

Non-
nationals 
65% 
53% 
7% 
10% 
- 
43% 
36% 
15% 
11% 

3rd nationals 

3% 
7% 
13% 
25% 
- 
4% 
1% 
3% 
8% 

11 Poland explained that these figures do not include police officers involved in roadside checks.  
12 This figure includes data from the UK, i.e. 5,142,962.  
13 Bulgaria (27%), Croatia (26%), Poland (25%) and Slovenia (22%) in the previous reporting period 2017-
2018.   

5 

 
 
                                                           
FR 
DE 
EL 
HU 
IE 
IT 
LV 
LT14 
LU 
MT 
NL 
PL 
PT 
RO 
SK 
SI 
ES 
SE 
TOTAL 

38% 
48% 
81% 
42% 
85% 
83% 
46% 
- 
29% 
38% 
39% 
59% 
95% 
83% 
45% 
47% 
91% 
54% 
63% 

60% 
47% 
13% 
47% 
14% 
15% 
35% 
- 
69% 
63% 
57% 
19% 
5% 
11% 
46% 
27% 
8% 
44% 
31% 

2% 
5% 
6% 
11% 
0% 
2% 
19% 
- 
2% 
- 
4% 
22% 
- 
6% 
9% 
26% 
1% 
2% 
6% 

5. Roadside checks – type of tachograph 

According to Article 2 of Directive 2006/22/EC, the threshold of minimum checks of number 
of days worked by drivers of vehicles will be raised to 4% once 90% of vehicles checked are 
equipped with a digital tachograph. 

Compared to the last report, the share of vehicles checked at the roadside that were equipped 
with  the  digital  tachograph  increased  from  71%  to  the  level  of  74%.  There  is  therefore  no 
base to raise the threshold of minimum checks to 4% for the time being. The highest share of 
digital  tachograph  (more  than  80%)  was  found  during  roadside  check  in  eleven  Member 
States:  Denmark  (96%),  Slovakia  (95%),  Austria  (94%),  Germany  (94%),  Sweden  (94%), 
Luxembourg  (91%),  Slovenia  (88%),  Czech  Republic  (86%),  Hungary  (86%),  Netherlands 
(86%), and  Ireland (83%). The number of Member States meeting the share of 90% digital 
tachographs  has  increased  from  five  to  six  since  the  last  reporting  period.  In  contrast,  the 
lowest percentage of digital tachograph was reported in Cyprus (30%) and Romania (40%). 
Table 3 below provides a full overview. 

Table 3: Overview of the number of vehicles stopped for roadside checks by type of tachograph 

%  
analogue 

Digital 
tachograph 

% 
digital 

MS 

AT 
BE 
BG 
HR 
CY 
CZ 
DK 

Analogue 
tachograph 
7228 
4113 
24279 
8013 
2663 
9331 
1350 

4% 
4% 
24% 
37% 
70% 
13% 
4% 

14 Lithuania did not provide this data. 

94% 
76% 
76% 
63% 
30% 
86% 
96% 

170863 
88251 
78561 
13485 
1135 
59521 
31130 

6 

Smart  
tacho 

3135 
23046 
- 
11 
1 
581 
- 

% 
smart 

2% 
20% 
- 
- 
- 
1% 
- 

 
 
                                                           
EE 
FI 
FR 
DE 
EL 
HU 
IE 
IT 
LV 
LT15 
LU 
MT 
NL 
PL 
-PT 
RO 
SK 
SI 
ES 
SE 
TOTAL 

2209 
5855 
80562 
46893 
49296 
8882 
716 
145613 
5726 
- 
572 
2 
2503,9755 
63282 
11950 
307540 
576 
1648 
38584 
2098 
831,485 

28% 
15% 
15% 
6% 
56% 
14% 
17% 
25% 
23% 
- 
9% 
25% 
10% 
19% 
30% 
59% 
5% 
12% 
9% 
6% 
20% 

5601 
28204 
380542 
761501 
38106 
56775 
3619 
446369 
18704 
- 
6095 
6 
22391,8963 
227723 
28242 
209684 
10193 
12002 
306760 
34490 
3,039,954 

71% 
72% 
71% 
94% 
44% 
86% 
83% 
75% 
77% 
- 
91% 
75% 
86% 
68% 
70% 
40% 
95% 
88% 
71% 
94% 
74% 

70 
5373 
75978 
1672 
- 
- 
- 
176 
- 
- 
- 
- 
1270,1282 
1.727 
- 
2240 
- 
5 
- 
- 
115,285 

1% 
14% 
14% 
- 
- 
- 
- 
- 
- 
- 
- 
- 
5% 
1% 
- 
- 
- 
- 
- 
- 
3% 

6. Checks at the premises 

The total number of working days checked at premises was 34,297,945 which is an increase 
compared to 33,673,792 working days checked at premises in the previous reporting period. 
In total, Member States checked 499,943 drivers during 2019-2020 (against around 641,000 
drivers  during  2017-2018),  which  confirms  a  decreasing  trend  regarding  the  amount  of 
drivers checked at the premises  with a 22% decrease compared to the previous period. The 
number  of  drivers  checked  at  the  premises  decreased  in  a  majority  of  the  Member  States, 
especially in Malta (-100%16), Croatia (-49%), the Netherlands (-49%) and Romania (-49%). 
However,  Greece  covered  significantly  more  drivers  during  their  checks  at  the  premises 
(+166%).  

In  this  reporting  period,  58,300  transport  undertakings  were  checked  (against  104,10417 
transport undertakings during 2017-2018), which is a 44% decrease compared to the previous 
period. Though the number of undertakings checked decreased in the majority of the Member 
States, some Member States covered more undertakings during their checks at the premises, 
namely Denmark (+109%), Belgium (+11%) and Ireland (+5%).  

The share of drivers checked at the premises compared to all drivers controlled at premises 
and roadside, continued to increase throughout the years with a share of 12% (11% share in 
2017-2018,  10%  share  in  2015-2016,  9%  2013-2014,  7%  in  2011-2013  and  5%  in  2009-
2010). Figure 1 presents the share of working days checked at the premises from 2013.  

15 Lithuania did not provided this data.  
16 No premises checks were done in Malta in 2019-2020. 
17 86.643 undertakings were checked in 2017-2018 without the UK.  

7 

 
 
 
                                                           
Figure 1: Share of working days checked at the premises in 2013-2020 per Member State 

Overview - Share of working days checked at 
premises

120%

100%

80%

60%

40%

20%

0%

T
A

E
B

G
B

R
H

Y
C

Z
C

K
D

I

E F
E

R
F

E
D

L
E

E
U I
H

T
I

V
L

T
L

U
L

T
M

L
N

L
P

T
P

O
R

I

K S
S

S
E

E
S

Share of working days checked at premises 2013-2014
Share of working days checked at premises 2015-2016
Share of working days checked at premises 2017-2018
Share of working days checked at premises 2019-2020

e
g
a
r
e
v
A
U
E

7. Offences – detection rate 

The average offence rate, which is calculated based on 100 working days checked at premises 
and roadside checks, decreased from 2.7 in 2017-2018 to 2.1 in the current reporting period.  

Significant  disparities  continue  to  exist  between  Member  States.  Seven  Member  States  are 
marking  the  total  lowest  offence  rate  (per  100  working  days)  in  the  EU:  0.12  in  Bulgaria, 
0.15  in  Latvia,  0.32  in  Hungary,  0.34  in  Romania,  0.66  both  in  Denmark  and  France,  and 
0.94  in  Lithuania.  At  the  same  time,  the  following  Member  States  have  very  high  offence 
rates: 8.39 in Cyprus, 6.61 in Austria, 5.77 in Poland.  

A  significant  increase  in  the  offence  rate  can  be  observed  in  Malta  (from  1,34  to  12,5018), 
Belgium (from 0.88 to 1.25), whereas a significant drop was reported by Greece (from 5.82 
to 1.59), Latvia (from 11.12 to 0.15) and Lithuania (from 18.72 to 0.94) and Finland (from 
6.83 to 2.65). The table in Figure 2 provides an overview of the development of the offence 
rate in EU Member States since 2013. Given these discrepancies, the enforcement practices 
across the EU should be aligned, leading to harmonised checks that have similar outcomes. 
The  Commission  services  are  currently  establishing  a  common  training  curriculum  for  EU 
enforcers to ensure that the training of enforcers in the EU adhere to a minimum standard19, 
to  ensure  that  enforcement  practices  are  harmonised,  and  to  integrate  new  elements  from 
Mobility  Package  I.  The  European  Labour  Authority  may  also  support  Member  States’ 
information and capacity building efforts.  

18 Yet, Malta checked only 8 vehicles at the roadside in the period 2019-2020.  
19 In line with Article 39(3) of Regulation (EU) No 165/2014.  

8 

 
 
 
 
                                                           
 
Figure 2: Total offence rate at the roadside and premises checked between 2013-2020 

Total offences rate (per 100 working days)

20,0

18,0

16,0

14,0

12,0

10,0

8,0

6,0

4,0

2,0

0,0

AT BE BG HR CY CZ DK EE FI FR DE EL HU IE IT LV LT LU MT NL PL PT RO SK SI ES SE

EU
Tot
al

2013-2014 7,2 2,7 0,0 1,6 5,3 1,7 0,3 2,5 1,7 0,6 4,0 3,1 0,5 1,5 2,7 0,5 4,1 1,3 3,0 2,4 2,7 1,9 0,4 4,6 1,9 1,9 3,7 2,2

2015-2016 7,6 2,3 0,0 1,6 6,3 2,6 0,4 1,9 2,5 0,5 3,9 8,3 0,4 1,3 2,4 16, 2,0 5,0 1,6 3,6 6,0 2,0 1,0 4,2 2,3 1,8 3,5 2,6

2017-2018 7,1 0,9 0,1 1,5 8,7 2,7 0,5 1,9 6,8 0,8 3,5 5,8 0,6 1,8 1,9 11, 18, 4,1 1,3 3,2 7,8 2,8 0,7 3,9 2,3 1,9 2,7 2,7

2019-2020 6,6 1,3 0,1 1,4 8,4 2,7 0,7 2,1 2,6 0,7 3,2 1,6 0,3 2,0 1,8 0,2 0,9 4,5 12, 2,7 5,8 1,8 0,3 3,5 1,7 1,5 2,3 2,2

8. Offences detected at the roadside 

On  average,  60%  of  all  detected  offences  were  found  during  roadside  controls  in  the  EU, 
which is a slight increase compared to 57% in the last report. The offence rates found at the 
roadside across the EU were very diverse. Compared to the EU average of 1.82 offences per 
100  working  days  checked,  offence  rates  are  particularly  high  in  Greece20  (12.77),  Malta 
(12.5021) and Austria (8.04), while significantly more than the EU average in Ireland (4.21), 
Estonia  (3.99),  Czech  Republic  (3.26),  (Luxembourg  (2.88)  and  Poland  (2.88).  Very  low 
offence rates at the roadside were reported in Finland (0.18), Bulgaria (0.21), Belgium (0.57), 
Croatia (0.61), Denmark (0.61), France (0.71), Hungary (0.15), Latvia (0.38), and Romania 
(0.63). A considerable increase in detection rate was observed in Malta (from 1.67 to 12.50), 
while a decrease was observed in Lithuania (from 10.23 to 0.65) and Luxembourg (from 3.51 
to 2.88), i.e. countries which reported increase in detection rate in 2017-2018.   

In  some  of  the  Member  States,  the  numbers  of  detected  offences  related  to  non-national 
vehicles  prevail,  namely  in  France  (91%),  Sweden  (86%),  Luxembourg  (74%),  Austria 
(72%), Bulgaria (66%),  Belgium (59%) and  Denmark (52%). This  may be  partly  explained 
by the fact that some of the Member States are transit countries.   

9. Offences detected at the premises 

On average, 40% of all detected offences were found during controls at the premises in the 
EU,  which  is  a  slight  decrease  compared  to  43%  in  the  last  report.  Offence  rates  at  the 

20 Greece has not met the threshold of working days checked at the roadside. 
21 Yet, Malta checked only 8 vehicles at the roadside in the period 2019-2020.  

9 

 
 
                                                           
 
premises of undertakings in the EU are also significantly diverging22. Several Member States 
were well above the EU average of 2.59 (4.3523 in 2017-2018) with the highest detection rate 
in the Netherlands (12.55), Cyprus (12.02), Poland (9.04), Germany (7.25) and Italy (4.21). 
This  stands  in  contrast  to  countries  with  a  very  low  detection  rate  such  as  Austria  (0.63), 
Bulgaria  (0.04),  Croatia  (0.84),  Denmark  (0.75),  France  (0.39),  Greece  (0.04),  Hungary 
(0.85), Portugal (0,04), Romania (0.03), Slovenia (0.66) and Spain (0.83).  

Compared to 2017-2018, there is a significant rise in detection rates in the Netherlands (from 
10.20 to 12.55) and  Luxembourg (from 4.40 to 7.61), while rates significantly decreased in 
Poland (from 16.68 to 9.04), Germany (from 8.94 to 7.25), Cyprus (from 13.55 to 12.02). 

10. Categories of infringements detected at roadside  

The  main  types  of  infringements  detected  at  the  roadside  by  Member  States  remained  on 
average relatively similar to the last report in terms of share of the total offences detected at 
the roadside.  

Offences on the recording equipment, which comprise offences on incorrect functioning and 
misuse  or  manipulation  of  the  tachograph,  remained  stable  in  2019-2020.  Incorrect 
functioning of the tachograph constituted the majority of this category with 9% of the overall 
offences, while manipulation and misuse of the tachograph constituted only 4% of the overall 
offences  (14%  in  2017-2018)  at  the  roadside.  However,  in  Estonia  (42%),  the  Netherlands 
(32%)  and  Romania  (32%)  manipulation  and  misuse  even  made  up  around  a  third  of  their 
offences  found.  In  Denmark,  this  category  of  infringments  constituted  about  62%  of  the 
overall offences.  

Looking  at  national  figures  for  other  types  of  infringements,  the  detected  infringements  on 
driving time were particularly high in  Luxembourg (36%), Malta (36%)  and France (34%), 
while  offences  on  breaks  were  high  in  Cyprus  (50%),  Ireland  (37%)  and  Slovakia  (35%). 
Offences on rest periods were significant in France (46%), Belgium (45%), Spain (44%), and 
Hungary  (40%).  In  the  Czech  Republic  (53%),  Latvia  (53%)  and  Italy  (44%),  the  share  of 
infringements  related  to  driving  records  is  significant  compared  to  the  majority  of  Member 
States. The EU average for infringements of providing records for other work is very low in 
the majority of Member States (EU average being 11%), but constitutes a greater share in the 
Member States such as Bulgaria (19%), Poland (17%) and Germany (16%).  

11. Categories of infringements detected at premises  

The  main  types  of  infringements  detected  at  the  premises24  of  undertakings  remain  stable 
compared to the last report. 

The  number  of  infringements  detected  regarding  breaks  increased  from  19%  to  24%,  rest 
periods from 16% to 17%, while infringements related to driving time (9%) remained stable. 
The number of infringements detected for driving time records also remained stable (40%). 
This  offence  was  significantly  noticed  at  the  premises  of  undertakings  in  Poland  (78%  of 

22 Latvia is not included, as number and type of offences detected at premises were not reported. Malta did not 
carry out checks at the premises in 2019-2020. 
23 UK were included.  
24 Latvia did not provide data on offences at the premises and Malta reported that no checked were performed at 
the premises.  

10 

 
                                                           
offences detected at premises), Italy (69%), and Hungary (62%). As explained previously by 
Italian  authorities,  the  low  fines  for  missing  driving  records  would  encourage  drivers  and 
operators to claim that they are not in possession of driving time records rather than risking to 
be fined for other offences that are subject to significantly higher fines. 

A high number of driving time offences was detected in Greece (52%),  Portugal (34%) and 
Lithuania  (31%).  Offences  on  breaks  were  frequently  detected  in  Ireland  (60%),  Denmark 
(54%),  Finland  (49%),  Cyprus  (45%)  and  Germany  (44%).  Infringements  on  rest  periods 
constituted  a  great  share  in  Estonia  (59%),  Romania  (57%),  Croatia  (48%),  Luxembourg 
(45%), and Portugal (45%).   

Offences  on  recording  equipment  constituted  3%  and  amounted  to  26,926  in  2019-2020. 
Their  national  share  was  particularly  high  in  France  (20%).  Infringements  on  the  lack  and 
availability of records of other work were in particular high in Sweden where they constituted 
23%  of  the  national  offences  detected  at  the  premises  (decreased  from  33%).  The  Swedish 
authorities explained that the numbers reported were higher because infringements related to 
not using manual input when required to do so were included25.  

Table 4: Breakdown of offences found at the roadside and premises in 2019-2020 

Checks at  Breaks 

Rest 
periods 

Driving 
time 

Roadside 
Premises26 
Total 

16% 
24% 
20% 

26% 
17% 
22% 

18% 
9% 
14% 

Driving 
time 
records 
18% 
40% 
29% 

Recording 
equipment 

13% 
3% 
8% 

Lack/availability 
of  records for 
other work 
9% 
6% 
8% 

12. Cooperation between Member States 

According to Directive 2006/22/EC, Member States are obliged to undertake no less than six 
concerted  roadside  checks  per  year  with  at  least  one  other  Member  State.  Not  all  Member 
States provided required information on concerted checks and exchange of information  and 
data. While it is understandable that the Covid-19 crisis prevented national authorities from 
organising  concerted  checks  in  2020,  thirteen  Member  States27  did  not  provide  information 
on  the  number  of  concerted  checks  or  did  not  provide  any  information  about  concerted 
checks  regarding  the  reporting  period.  Out  of  the  14  Member  States  that  did  provide 
information on checks, 12 Member States28 met the required number of concerted checks in 
the reporting period, especially in 2019.  

Most  Member  States  participated  in  concerted  checks  through  the  European  Traffic  Police 
Network  (ROADPOL)29  and  Euro  Control  Route  (ECR)  cooperation.  The  support  of  the 

25 Reference is made to H16 in the appendix III of Regulation (EU) No 2016/403. 
26 Latvia did not provide categorisation of offences at the premises. 
27 Belgium, Croatia, Cyprus, Czech Republic, Denmark, Finland, Greece, Malta, the Netherlands, Portugal and 
Slovenia. Hungary and Malta informed that no concerted checks were carried out. 
28  Austria,  France,  Germany,  Ireland,  Italy,  Latvia,  Lithuania,  Luxembourg,  Poland,  Romania,  Slovakia  and 
Spain.  
29 The statutes of the new European Public Association called “ROADPOL European Roads Policing Network” 
were  signed  in  Dublin  on  26  September  2019  and  will  replace  TISPOL  from  the  year  2020,  maintaining  the 
same objectives. 

11 

 
 
                                                           
CORTE  Enforcement  working  group  was  also  indicated.  A  number  of  Member  States 
reported  great  satisfaction  of  participants  in  the  concerted  checks  and  other  forms  of 
cooperation.  It  was  affirmed  that  joint  road  checks  contribute  to  knowledge-sharing  on 
carrying out checks, reviewing and harmonising positions on the understanding of particular 
provisions  of  European  legislation  and  exchanging  experiences  on  the  use  of  assessment 
programmes. 

Table 6 below presents the number of concerted checks and exchange of experience carried-
out  by  Member  States  in  2019-2020.  It  also  provides  an  overview  of  the  focus  of  these 
concerted checks and exchanges of experience, as well as information on the Member States 
involved.  

Table 5: Overview of concerted checks per Member State 

Austria 

2019  
Concerted checks:  
  6 with ECR/Tispol Member States 

2020 
Concerted checks:  
  5 with ECR/Tispol Member States 

Belgium 

Bulgaria 

2019-2020 
Exchange of experience and information: 3 bilateral (9 persons involved) and 
2 multilateral (6 persons involved) with ECR/Tispol Member States. Subject 
of the exchange: Driving time checks, Manipulation of recording equipment, 
technical checks, Securing cargo. 
2019-2020 
Concerted checks: 
No information provided 

Exchange of experience and information:   
Exchange of information via online meetings on the crisis and about the 
temporary measures that were taken to help the sector. 
2019 
Concerted checks:  
  2 joint inspections with Romanian control bodies (ARR) in Romania and 

Bulgaria. 

Exchange of experience and information: 
  Exchange of information on established violations committed by 

Bulgarian drivers on the territory of Germany, Hungary, Austria, Spain, 
United Kingdom, Italy, Latvia, Romania, Slovenia. 

2020 
Concerted checks:  
  2 joint inspections with Romanian control bodies (ARR) in Romania and 

Bulgaria. 

12 

 
 
 
 
 
 
                                                                                                                                                                                     
 
Exchange of experience and information: 
  Exchange of information on established violations committed by 

Bulgarian drivers on the territory of Germany, Hungary, Austria, Spain, 
United Kingdom, Italy, Latvia, Romania, Slovenia. 

Croatia 
Cyprus 
Czech 
Republic 

No information provided 
No information provided 
2019 
No information provided 

Denmark 
Estonia 

2020 
No joint controls organised due to the Covid-19. 
No information provided 
2019 
Concerted checks: 
  2 common roadside checks of the Estonian Police and Border Guard: one 
with the Latvian enforcement authorities and one with the Finnish Police.  

Finland 
France 

2020:  
  No common road side checks  

Exchange of experience and information: 
No information provided 
No information provided 
2019 
Concerted checks: 
  6 weeks of coordinated checks within ECR were spread over the year  

with the following topics: 
enterprise fraud, tachograph fraud and anti-pollution devices  
technical roadside inspection 
transport of dangerous goods 
transport of passengers 

- 
- 
- 
- 
France participated in all weeks of planned inspections. 

Exchange of experience and information: 
  France organised a week-long exchange cooperation session in Bordeaux, 
which brought together some thirty inspectors from all the Member States 
affiliated to ECR. In this context, various working themes were 
discussed, such as the fight against new forms of tachograph fraud 
(software), technical roadside inspection, AdBlue fraud. Enforcement 
officers from different countries presented their enforcement 
methodologies and highlighted their strengths and limitations. 
  France and Germany organised a bilateral exchange session which 
brought together some fifteen German and French officials. These 
sessions are now organised one year in Germany and the following year 
in France. The health crisis prevented the 2020 session from being held in 
France. 

  Participation in : 
- 

"training sessions on tachograph fraud organised by TISPOL and ECR 

13 

 
 
 
 
 
 
- 

(two sessions are organised each year in Osnabruck, where two inspectors 
participated) 
the "tachy work group" (TWG) and the "ADR" working group on the 
transport of dangerous goods, which bring together experts from all ECR 
Member States. 

These working groups also make it possible to update the control methods 
and to find out about the latest frauds encountered by the controllers of the 
various States and the means put in place to combat them.  

2020 
Concerted checks: 
  one coordinated check in February on enterprise fraud, tachograph fraud 

and anti-pollution devices.   

Germany 

Greece 
Hungary 

Exchange of experience and information: 
In the second half of the year 2020, a TWG group was held remotely.  
Concerted checks in 2019-2020: 
  Total of 39 joint checks. 
No information provided 
2019-20 
Concerted checks: 0 

Ireland 

Italy 

2019-20 
Exchange of experience and information: 
  The cooperating countries were: Czech Republic, Slovakia, Austria, 

Poland. The most common data exchange was due to vehicles in poor 
technical condition.  

2019-2020 
Concerted checks: 
  16 - tripartite - Ireland, UK & Northern Ireland (UK - DVA, NI - DVSA 

& IRL - RSA) 4 weeks per annum, 2 per week. 

Exchange of experience and information: 
  4 - 5 ECR exchanges depending on COVID situation. 
2019 
Concerted checks: 
  12 joint  operations at  European level  in  which the  Italian  Traffic Police 
participated. As a part of the joint European ‘Truck and Bus’ campaign, 
four  ‘Truck  and  Bus’  operations  were  carried  out  in  Italy  in  February, 
May, July and October, during which 3717 infringements were detected 
in respect of driving time and rest periods and the smooth operation of the 
tachograph in general. 

2020 
Concerted checks: 
  5 joint operations at European level in which the Italian Traffic Police 

participated. As a part of the joint European ‘Truck and Bus’ campaign, 
the following operations were carried out: 
•  2 Truck & Bus operations, to check professional drivers of vehicles 
used for the transport of persons and goods: 10-16 February and 12-

14 

 
 
 
 
 
 
18 October 2020;  

•  1 operation Seatbelt, to check the correct use of restraint systems: 9-

15 March 2020;  

•  1 operation Focus on the Road, for the correct use of mobile phones, 

smartphones: 14-20 September 2020;  

•  1 Alcohol & Drugs operation, in order to verify the psychological and 
physical conditions relating to the possible consumption of alcoholic 
beverages and drugs by drivers of motor vehicles: 7-13 December 
2020.   

Latvia 

2019 
Concerted checks: 
  6 common roadside checks with Lithuania and Estonia  

2020  
Concerted checks: 
  6 common roadside checks with Estonia and Lithuania. 

Lithuania 

Exchange of experience and information: 
No data 
2019-2020 
Concerted checks:  
  21 joint vehicle controls with Polish and Latvian inspectorates  

Exchange of experience and information: 
No data 

Luxembourg  2019 

Concerted checks: 
Administration des Douanes et Accises : 
  14 joint controls with la Dreal (France)  
  1 joint control 2/9/2019-5/9/2019 with Spain, Germany, Poland, Croatia, 

the Netherlands, Czech Republic and France. 

Exchange of experience and information: 
Officers participated in exchanges/training ECR 

2020  
Concerted checks: 
  7 joint controls with la Dreal (France) 

Police grand-ducale: 
  Checks with Germany within "Freisener Gespräche" 
No concerted check carried out in the reporting period 

Malta 

Netherlands  2019 

Concerted checks: 
  ECR/TISPOL audits  

Exchange of experience and information: 
  Multilateral exchanges with France (2x) 
  Bilateral exchange with Germany (12x) 

15 

 
 
 
 
 
 
 
 
Poland 

  Masterclass 1 (1x) and Masterclass 2 (2x) 

2020 
No Concerted checks  
No Exchange of experience 
2019  
Concerted checks as part of ECR (Euro Contrôle Route) 
- Week 8, focus: Truck and Bus – DRT & manipulation 
- Week 15, focus: Truck and Bus – Manipulation 
- Week 20, focus: Truck and Bus – DRT & manipulation 
- Week 30, focus: Truck and Bus – Holiday buses & passenger transport 
- Week 38, focus: Truck and Bus - ADR 
- Week 42, focus: Truck and Bus – DRT & manipulation 
- Week 47, focus: Truck and Bus – Technical condition 
In total, during the coordinated weeks of inspections, Road Transport 
Inspection inspected a total of 22,500 vehicles in which 11165 infringements 
were found. 

Exchange of experience and information: 

•  Poznań, Poland, May 12-17, 2019 - trilateral exchange CZ-DE-PL 

exchange-technical condition of vehicles and tachograph 
manipulations 

•  Katowice, Poland, June 24-27, 2019 - multilateral exchange NL-CZ-
DE-RO-HR-HU-BE-LU-CH exchange - ACE (ADR Crossborder 
Enforcement) 

•  Bordeaux, France, June 23-28, 2019 - multilateral exchange BE-NL-

LU-DE-RO-CZ-HU-IE- PL-FR-HR-ES on manipulation of 
tachographs, technical inspection of vehicles and manipulation of 
AdBlue systems. 

•  Osnabrück, Germany, July 8-12, 2019 - multilateral exchange ECR 

ADR Expert Class (dangerous goods) 

•  Osnabrück, Germany, July 15-19, 2019 - multilateral exchange ECR 

Master Class - tachograph manipulations 

•  Luxemburg, September 2-5, 2019 - multilateral exchange ACE (ADR 

Crossborder Enforcement) 

•  Villingen, Germany, September 9-11, 2019 - international workshop 
on the introduction of smart tachographs and the latest manipulation 
methods 

•  Vilnius, Lithuania, October 3, 2020 - bilateral cooperation regarding 

regulation of PL-LT carrier activities and inspections 

•  Osnabrück, Germany, October 7-11, 2019 - ECR Master Class 

tachograph fraud 

•  Bristol, England, October 7-10, 2019 - ECR Enforcement 

Transformation Exchange 

•  Paris, France, October 28-30, 2019 – Meeting of the ADR Working 

Group on Monitoring of Roadside Checks 

2020 
Concerted checks: 
- Week 7, focus: Truck and Bus - DRT & manipulation 

16 

 
 
 
 
- Week 11, focus: Truck and Bus - Manipulation & SCR systems 
- Week 30, focus: Truck and Bus - Driving and resting times (Holiday buses 
& passenger transport) 
- Week 38, focus: Truck and Bus - ADR 
- Week 42, focus: Truck and Bus - DRT & manipulation; 
- Week 47, focus: Truck and Bus - Technical condition 
In total, during the coordinated weeks of inspections, Road Transport 
Inspection inspected a total of 13,284 vehicles in which 4602 infringements 
were found. 

Exchange of experience and information: 
  Due to the COVID-19 pandemic restrictions, international meetings, 
including foreign delegations, were cancelled or held online as 
videoconferences  

  Events organized by the European Commission 
  The participation of the representatives of Road Transport Inspection 
(ITD) in events organized by the European Commission, i.e. the Road 
Transport Committee, the Tachograph Forum and the Enforcement 
Working Group (EWG) - the newly created task force of the European 
Commission dealing with enforcement, was ensured. In terms of other 
activities at the European Commission, ITD experts took active 
participation in the operations of new working groups, i.e. the expert 
group on roadworthiness and vehicle registration documents (RWEG) 
and the expert group on the transport of dangerous goods (TDG). 
International meetings, where Road Transport Inspection participated, the 
more important ones being: 
-  Kyiv, Ukraine, January 29, 2020 - bilateral UA-PL exchange - 

 

bilateral cooperation 

-  Warsaw, Poland, March 3, 2020 - bilateral LT-PL exchange of 

information on control procedures and prospective cooperation within 
the international organization ECR 

-  participation of ITD representatives in ECR working groups, 

including ECR - Training, which deals with the implementation of 
training tasks; ECR - Harmonie, responsible for the implementation 
of coordinated control weeks in the Member States, as well as the 
exchange of information on infringements and standardization of 
control procedures through development of common interpretation of 
regulations implemented into the legal systems of individual Member 
States; and Tacho Web Group - the ECR expert group dealing with 
manipulations in tachographs. As part of the working subgroups 
participation in: ECR DRT, ECR ADR, Data Exchange, ECR 
Harmonie Cargo Securing & Technical 

-  videoconference: "Digital enforcement of EU road transport 
regulations", online workshop on road transport organized by 
European Labour Authority (ELA), IRU, Commission on Social 
Affairs Workshop 
as part of establishing bilateral relations and possible cooperation 
within the framework of Euro Contrôle Route, the following 
videoconferences were organized: 
- September 18, 2020 PL- MD videoconference 

- 

17 

 
 
- September 21, 2020 PL-UA videoconference 
- November 27, 2020 PL- AL videoconference 
- December 2, 2020, PL-UA videoconference 
- December 2, 2020, PL-TR videoconference. 

Portugal 

No specific information provided except that Portugal has participated in the 
relevant meetings organised by the competent bodies at Community level 

Romania 

Slovakia 

2019 
Concerted checks: 
  7 concerted checks organized by ECR, with the participation of ECR 
members, authorities from Austria, Netherlands, France, Belgium, 
Poland, United Kingdom, Ireland, Lithuania, Spain, Bulgaria, Hungary, 
Luxembourg, Croatia, Germany and Romania. Romania participated to 
all coordinated controls. 

  2 bilateral roadside checks organised between RO-HU (15-16.04.2019, 
25-26.09.2019) with main subjects: social legislation, tachograph 
manipulation, technical conditions for passenger and freight transport.      

Exchange of experience and information: 
  2 multilateral exchanges of experience organized in France, Bordeaux 

(23-28.06.2019) and in Netherlands, Leiden ( 03-08.11.2019)  under the 
aegis of ECR. 

  2 master classes organised in Germany, Osnabruck (15-19.07.2019; 07-

11.10.2019) under the aegis of ECR.  

2020 
Concerted checks:  
  8 concerted checks organized by ECR to which were invited to 

participate ECR members, authorities from Austria, Netherlands, France, 
Belgium, Poland, United Kingdom,  Ireland, Lithuania, Spain, Bulgaria, 
Hungary, Luxembourg, Croatia, Germany and Romania. Romania 
participated to all coordinated controls.                                                                                                                                              

Exchange of experience and information: 
No exchange of experience between roadside inspectors were organised due 
to the pandemic year.  
2019 
Concerted checks: 
  Joint control actions carried out with the Czech Republic (Centrum 

služeb pro silniční transport), Hungary (Nemzeti Közlekedési Hatóság), 
and Poland (Inspekcja Transportu Drogowego). The inspectors controlled 
social legislation in transport with the Czech Republic and Poland, and 
detected tampering with recording equipment with Hungary.  
-  23-25 September 2019, the NIP in Žilina Region organised the 6th 
International Control of Social Transport Legislation with the 
participation of five countries (Slovakia, Czech Republic, Hungary, 
Poland, Ukraine) with accommodation in Mala Lučivná. Several 
labour inspectorates, as well as labour inspectors, with knowledge of 
a foreign language (Hungarian and English) were needed to ensure 
the control action. For this reason, several labour inspectorates 

18 

 
 
                                                                                                                                                                                                                                                                      
 
cooperated with the NIP in the inspection action in question: IP 
Žilina, IP Košice, IP Nitra, IP Banská Bystrica and IP Bratislava. 26 
participants took part in the International Scrutiny Action and carried 
out checks at two checkpoints:   
1.  Kysucký Lieskovec (route Žilina - Poland) - 2 checks; 
2.  Sub-dry (directed Ružomberok - Banská Bystrica) - 2 checks. 
On 24 September 2019, the checks at the Podsuchá control station 
were attended by media representatives: RTVS and TASR. The 
international inspection report was broadcast in the RTVS TV 
newspaper on 24 September 2019. 

2020 
Concerted checks: 
No joint controls carried out in 2020.  

No information provided 
2019  
Concerted checks: 
  7 ECR coordinated controls, organized by ECR-TISPOL (passengers and 
goods), about the following topics: driving and resting times, tachograph 
manipulation, holiday buses and passenger transport, ADR, technical 
condition. 

2020  
Concerted checks: 
  2 (out of 8 planned) ECR coordinated controls, organized by ECR-

TISPOL (passengers and goods) took place in Spain. 

2019 
Concerted checks: 
  One planned concerted check was conducted with Norway and Denmark.  
  Several spontaneous concerted controls have been conducted with 

Finland and Denmark. 

2020 
No concerted checks during 2020 due to the pandemic. 

Slovenia 
Spain 

Sweden 

13. Penalties 

Article 19 of Regulation (EC) No 561/2006 sets out that Member States shall lay down rules 
on  penalties  that  are  to  be  effective,  proportionate,  dissuasive  and  non-discriminatory. 
Member States shall notify the Commission of these measures and the rules on penalties. For 
the  current  report,  most  Member  States  reported  in  the  area  and  some  reported  changes  in 
2019-202030.  

Denmark has  a  graded  fines system in  which the fee  for the  driver must  be  graduated with 
fees  for  minor  infringements  being  DKK  500  and  for  the  most  serious  infringements  DKK 
6,000.  Similarly,  the  fee  for  the  undertaking  must  be  graduated  with  fees  for  minor 
infringements  being  DKK  1,000  and  for  the  most  serious  infringements  DKK  12,000.  In 

30 Denmark, Finland, Latvia and the Netherlands. 

19 

 
 
 
 
 
                                                           
Denmark, new rules31 entered into force on 1 March 2020 introducing a fine level for illegal 
weekly rest taken in the vehicle, so that taking regular weekly rest in the vehicle is considered 
a special aggravating circumstance. Thus, the fine for the driver is DKK 10,000 per offence 
and the fine for the undertaking is DKK 20,000 per offence.  

In  Latvia,  a  Law  on  Administrative  Liability  replaced  the  Latvian  Code  of  Administrative 
Offences since 1 July 2020. The main changes are that each offence is now sanctioned with a 
separate fine. Until that date, if there was more than one infringement, the fine was inclusive 
(the offender was fined only for the most severe offence).   

The Bulgarian authorities confirmed that the increased amount of sanctions for some offenses 
had a deterrent effect, leading to a reduction in traffic offenses and an increase in road safety. 

In the Netherlands,  as  of 1 January 2019, fines  for tachograph fraud in  road transport have 
been significantly increased. Employers who cause their drivers to violate the legislation on 
working time and rest periods are liable to a fine of up to EUR 10,375. Previously, the fine 
was EUR 1500 or EUR 4400. For the driver working as an employee, the fine is EUR 1500. 
The strengthening of the penalty regime is intended to encourage undertakings and drivers to 
record driving times and rest periods more correctly and accurately. 

At  the  time  of  writing  this  report,  a  new  Article  19(1)  of  Regulation  (EC)  No  561/2006 
adopted under Mobility Package I has started applying on 20 August 2020. According to this 
Article, Member States are obliged to inform the Commission about changes to penalties, and 
the Commission is required to publish this information on a dedicated website in all official 
EU  languages32.  The  information  related  to  national  penalties  is  available  on  the 
Commission’s website33.   

14. Exceptions granted by Member States 

According  to  Article  13  of  Regulation  (EC)  No  561/2006,  Member  States  may  grant 
exceptions  from  the  application  of  provisions  on  driving  times,  breaks  and  rest  periods, 
provided  that  certain  specific  conditions  are  met  and  that  the  overall  objectives  of  the 
Regulation are not prejudiced. Member States are obliged to inform the Commission of the 
exceptions granted.  

In addition, according to Article 14(2) of Regulation (EC) No 561/2006, Member States may 
also  grant,  under  exceptional  circumstances,  temporary  exceptions  on  driving  times,  breaks 
and  rest  periods  for  a  period  not  exceeding  30  days.  The  wide  majority  of  Member  States 
adopted  temporary  exceptions  due  to  the  Covid-19  crisis  in  2020.  Furthermore,  some  of 
Member  States  also  requested  the  authorisation  to  the  Commission  to  grant  temporary 
exceptions under Article 14(1) of the Regulation.  

31 Act No 139 of 25 February 2020 amending the Road Traffic Act.  
32 Regulation (EU) 2020/1054 of the European Parliament and of the Council of 15 July 2020 amending 
Regulation (EC) No 561/2006 article 19(1). 
33 https://transport.ec.europa.eu/transport-modes/road/social-provisions/enforcement_en  

20 

 
                                                           
 
The  table  below  illustrates  the  exceptions,  which  have  been  introduced  since  the  entry  into 
force  of  Regulation  (EC)  No  561/2006.  The  information  is  also  available  on  the 
Commission's website34.  

34 https://ec.europa.eu/transport/sites/transport/files/national_exceptions_regulation_2006_561.pdf 

21 

 
 
                                                           
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X  X  X  X3  X 

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X4  X  X4  X4  X4  X 

X4  X4  X 

X4  X  X4  X4  X4  X4 

X  X4  X4  X  X 

X  X4 

X5  X5  X5  X5 

X5  X5  X5 

X5 

X5 

X5  X5 

X5  X5 

X6  X6  X6  X  X6  X6  X6  X 

X6  X 

X6 

X6  X6  X  X 

X  X6 

X 

X 

X  X  X 

X 

X  X 

X  X7  X 

X  X7 

X 

X 

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X  X 

X 

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X8  X  X  X 

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X  X  X 

X  X8  X  X  X 

X  X  X 

X  X 

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X  X  X  X 

X 

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X 

X 

X  X  X9  X  X9  X  X  X 

X 

X 

X 

X 

X 

X 

X 

X  X  X 

X 

X 

X 

X11  X 

X 

X 

X12  X  X  X 

X 

X 

X 

X 

X 

X 

X 

X  X  X 

X  X 

X 

X 

X 

X 

X 

X 

X  X  X11  X  X11  X11 

X 

X 

X 

X  X  X 

X  X 

X 

X 

X 

X  X  X11  X11  X 

X  X 

X  X  X 

X 

X 

X 

X  X  X  X12 

X  X13  X  X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X  X  X  X  X10  X 

X  X  X  X 

X 

X  X  X  X  X11  X 

X  X  X  X 

X 

X  X  X  X 

X 

13.1 a: non-competing 
public authorities1 
13.1 b: agricultural etc. 
own activity < 100 km2 
13.1 c:agricultural/forestry 
tractors <100 km3 
13.1 d: <7,5 tons universal 
services <100 km4 
13.1 e: operating on islands 
or regions isolated from the 
rest of the national territory  
<2300 square km5  
13.1 f: <7,5 t <100 km gas/ 
electricity6 
13.1 g:  
instruction/examination 
driving licence/CPC7 
13.1 h: sewerage/flood 
protection/water etc8 
13.1 i: non-comm.  
passenger transp. between 
10-17 seats9 
13.1 j: circus/funfair10 

13.1 k: mobile projects for 
education 
13.1 l: milk/animal feed 
from/to farms11 
13.1 m: transporting 
money/ valuables12 
13.1 n: animal waste or 
carcasses13 

 
 
      
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
13.1 o: hub facilities14 

13.1 p: live animals farms -
> markets and vice versa 

13.1 q: construction 
machinery <100km  
13.1 r: ready-mixed 
concrete 

X 

X  X  X 

X 

X  X 

X 

X 

X  X  X 

X 

X 

X 

X14  X 

X  X  X  X 

X 

X  X15 

X15  X15  X15  X  X15  X15  X15  X 

X1
5 

X 

X15  X15 

X15  X15  X 

X 

X 

X1
5 

X 

X 

X 

X 

X 

X 

1.  The following Member States introduced additional restrictions:  

a.  Estonia - within a radius of 50 km of the place where the vehicle is usually based, including towns within this area 
b.  France - only vehicles or combinations of vehicles up to 7,5 tonnes and only within a radius of 50 km 
c.  Greece – only vehicles owned by owners of self propelled combine harvesters, used or hired without a driver by agricultural undertakings, for carrying goods 

as part of their own entrepreneurial activity within a radius of up to 100 km from the operational base that the combine harvester has each time. 

d.  Slovenia – within a radius of up to 50 km 
e.  Spain – agriculture etc. own activity within a range < 50 km  

2.  The following Member States introduced additional restrictions: 

a.  Slovenia - within a radius of up to 50 km 

3.  The following Member States introduced additional restrictions: 

a.  Belgium, Croatia, Cyprus, Czech Republic, Finland, France, Hungary, Italy, Latvia, Lithuania, Luxembourg, Poland, Portugal, Spain – within a radius < 50km 

4.  The following Member States introduced additional restrictions: 

a. 

In Cyprus, Czech Republic, Denmark, Germany, Croatia, Finland, Ireland, Malta, Poland, Portugal, Spain and Sweden  the old exceptionstill applies, namely 
“vehicles operating exclusively on islands not exceeding 2 300 square kilometres in area which are not linked to the rest of the national territory by a bridge, 
ford or tunnel open for use by motor vehicles” 

b.  Old exception still applies in France for vehicles operating on islands <400 square km 
c.  Old exception still applies in Spain for vehicles operating on islands < 250 square km 

5.  The following Member States introduced additional restrictions: 

a.  Croatia, Cyprus, Czech Republic, Estonia, Finland, France, Hungary, Lithuania, Poland, Portugal, Spain – within a radius < 50km 

6.  The following Member States introduced additional restrictions: 

Italy - it refers only to the obligation of equipping and using tachograph 

a. 
b.  Luxembourg - exception only for the (learning) driver, instructor must respect Regulation (EC) No 561/20006 

7.  The following Member States introduced additional restrictions: 

a.  Austria: 

(a) vehicles used by the regional authorities’ road construction offices and driven by employees of the provinces or municipalities are entirely exempted 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
(b) vehicles used in connection with sewerage, flood protection, water, gas and electricity supply, telegraph and telephone services, radio and television 
broadcasting, and the detection of radio or television transmitters or receivers are entirely exempted where driving of vehicles does not constitute the driver’s 
main activity 
(c) vehicles used by household refuse collection authorities are exempted only from the rules on breaks under Article 7 of Regulation (EC) No 561/2006 
(d) vehicles used in winter by road construction offices, where not covered by the exemption under point 9 a.(a), are exempted only from the rules on breaks 
under Article 7 of Regulation (EC) No 561/2006  

b.  France - for door-to-door household refuse collection and disposal, only within a radius of 100 km 

8.  The following Member States introduced additional restrictions: 

a.  Estonia - owner/authorised user of a vehicle with 10-17 seats who is a parent of 4/more children, respective entry made on a registration certificate of the 

vehicle and the vehicle is used for non-commercial passenger transport 

b.  France -  not for the transport of children 

9.  The following Member State introduced additional restrictions: 

a.  Spain - only when own activity 

10.  The following Member States introduced additional restrictions: 

a.  Austria - vehicles used to collect raw milk from farms exempted only from the rules on breaks under Article 7 of Regulation (EC) No 561/2006 
b.  Estonia, Latvia and Lithuania, as of 1/01/2008, mutually apply the exception from Articles 5 to 9 to vehicles used for milk collection from farms,...etc.,  only 

in cases where the service radius does not exceed 100 km 

c.  France - within a radius of up to 150 km of the base of the undertaking 
d.  Germany – within a radius of 100km 
e.  Spain – milk/animal feed from /to farms within a range < 100 km 

11.  The following Member States introduced additional restrictions: 

a.  Austria – exception only from the rules on breaks under Article 7 of Regulation (EC) No 561/2006 
b. 

Ireland - vehicles specially designed for mobile banking, exchange and saving transactions 

12.  The following Member State introduced additional restrictions: 

a.  Germany - within a radius of up to 250 km of the base of the undertaking 

13.  The following Member State introduced additional restrictions: 

a.  The Netherlands – on or between hub facilities within a range of 5 km 

14.  The following Member State introduced additional restrictions: 

a.  Belgium, Croatia, Cyprus, Czech Republic, Estonia, Finland, France, Hungary, Latvia, Lithuania, , Poland, Portugal, Spain– within a radius < 50km 

 
 
 
15. Comments and proposals  

A number of Member States provided comments and proposals related to the enforcement of 
the EU road transport social rules.  

Some  Member  States  referred  to  the  training  of  enforcers  at  national  level.  Austrian 
authorities reported on the continuation of the training programme for the inspection bodies 
of  their  Federal  Ministry  of  the  Interior  and  the  Federal  Ministry  of  Labour,  Social  Affairs 
and  Consumer  Protection.  This  covers  social  legislation  and  the  detection  of  manipulation 
based  on  the  TRACE  project35.  The  Slovak  authorities  reported  a  lack  of  knowledge  of 
occupational  safety  and  health  rules  in  all  undertakings,  which  have  a  transport  activity  as 
part of the activities or carry out that activity in the context of another business.  

The Netherlands brought attention to increasing knowledge and, where necessary, purchasing 
equipment.  The  Netherlands  focuses  on  acquiring  the  appropriate  technology  in  order  to 
better  monitor  and  investigate  more  drivers  digitally  at  the  beginning  of  2022.  The 
Netherlands  also  stressed  the  importance  of  active  working  groups,  meetings  and  direct 
contacts with manufacturers, the European Commission and JRC (EC Joint Research Centre) 
to disseminate knowledge on new tachograph manipulation. In addition, they pointed out that 
any  undesirable  development  in  the  field  of  tachograph  manipulation  required  intensified 
controls,  resulting  in  lengthy  and  complex  investigations.  A  new  registration  system 
(Holmes), offers more possibilities for the inspector to indicate how many driving days have 
been actually checked during company inspections.  

Slovakia  shared  the  fact  that  the  ratio  of  detected  deficiencies  per  working  days  checked 
increased  in  the  country  in  2020,  which  means  that  it  is  necessary  to  continue  to  raise 
awareness of the legislation among drivers and employers, to improve the quality of drivers 
checks and to train labour inspectors. However, there is still a need to initiate a change in the 
legislation concerning the controls of social legislation in the transport sector, as the changes 
in the law made in previous periods have not had the desired effect. 

A  number  of  Member  States  pointed  out  that  digital  tachographs  and  related  computerised 
enforcement  systems  improved  the  quality  of  checks  and  hence  the  enforcement  of  social 
legislation.  Indeed,  Member  States  indicated  that  the  data  recorded  in  digital  tachographs 
significantly  reduce  the  possibility  of  concealment  or  falsification  and  increases  drivers’ 
compliance  with  social  legislation.  The  new  smart  tachograph  2,  whose  technical 
specifications were adopted in 202136, will allow even more data to be recorded to facilitate 
the  enforcement  of  the  new  social  rules,  such  as  border  crossings  and  loadings  and 
unloadings.  Together  with  increased  awareness,  this  should  lead  to  more  efficient  and 
intelligent enforcement of social legislation in road transport. 

Italian authorities reported difficulties due to the complexity and detailed rules of the controls 
at  the  premises,  which  involve  a  considerable  effort  with  significant  human  and  material 

35https://transport.ec.europa.eu/transport-modes/road/social-provisions/enforcement_en 
36  Commission  Implementing  Regulation  (EU)  2021/1228  of  16 July  2021  amending  Implementing  Regulation  (EU) 
2016/799 as regards the requirements for the construction, testing, installation, operation and repair of smart tachographs and 
their components. 

25 

 
 
                                                           
 
resources.  They  still  face  the  challenges  in  achieving  the  required  ratio  of  checks  at  the 
premises. 

The Swedish authorities commented on the content of the biennial report. They pointed out 
that the report should reflect all infringements according to Annex III of Regulation (EU) No 
2016/403, as many infringements of other specific articles are not included, e.g. the number 
of vehicles stopped for roadside check by type of tachograph is not the same as the number of 
vehicles stopped for roadside check by type of road and by country.   

16. Interpretation of Regulation (EC) No 561/2006 and Directive 2002/15/EC 

In  the  recent  years,  the  Court  of  Justice  of  the  European  Union  (CJEU)  shed  light  on 
interpretation  of  Regulation  (EC)  No  561/2006  by  means  of  the  rulings  in  Case  C-834/18 
Rolibérica37.  The  question  at  stake  was  whether  the  Regulation  is  to  be  interpreted  as 
meaning  that  the  ‘weekly  rest  period’  for  drivers  involved  in  the  carriage  of  goods  and 
passengers by road, within the meaning of Article 8 of the Regulation, must begin and end 
between 00.00 hours on Monday and 24.00 hours on Sunday (having regard to the definition 
of  the  term  ‘week’  in  Article  4(i))  or,  on  the  contrary,  can  it  be  taken  completely  and 
uninterruptedly between two working weeks.  

In  its  order  of  10  April  201938,  the  CJEU  ruled  that  the  Regulation  561/2006  is  to  be 
interpreted  as  meaning  that  the  'weekly  rest  period'  within  the  meaning  of  Article  8  of  that 
Regulation does not necessarily have to end in the course of the 'week', as defined in Article 
4(i) of that Regulation.  

Regarding judicial interpretation by national courts, the Member States reported few national 
Court decisions interpreting Directive 2002/15/EC during 2019-2020. Most rulings regarded 
the interpretation of breaks, rest periods and ‘periods of availability’.  

Estonia reported that legal disputes concerning the implementation of Directive 2002/15/EC 
had been settled by the courts of first instance and there were no rulings by the highest court.  

Sweden also reported that only a few cases were subject to judicial review, but there were no 
guidance rulings issued by the higher courts. 

In Spain, there were a number of court cases related to collective agreements, working time, 
breaks, periods of availability concerning, for example, the calculation of hours of presence at 
the employer’s disposal, payments for more than 20 hours of availability, and the payments 
of daily allowances.  

The  Bulgarian  authorities  informed  that  they  do  not  have  any  information  available  on  the 
specific  interpretation  or  application  of  Directive  2002/15/EC  in  the  rulings  of  the  national 
courts, nor any relevant problems encountered in the exercise of control under the Directive, 
which appears to be effective.   

17. Monitoring and control arrangements of Directive 2002/15/EC in Member States 

37 https://curia.europa.eu/jcms/jcms/P_126035/en/ (https://eur-lex.europa.eu/legal-
content/en/TXT/?uri=CELEX:62018CO0834) 
38 https://eur-lex.europa.eu/legal-content/en/TXT/?uri=CELEX:62018CO0834 

26 

 
 
                                                           
All Member States implemented Directive 2002/15/EC. The monitoring of implementation of 
the Directive  is  ensured  at  national level by different  authorities depending on  the Member 
State.  The  bodies  responsible  for  the  monitoring  and  control  arrangements  of  Directive 
2002/15/EC  can  be  the  labour  inspectorate,  road  transport  agency,  occupational  health  and 
safety authority, police, road safety authorities and road transport inspections.  

18. Issues in relation to enforcement of Directive 2002/15/EC 

A  majority  of  Member  States  did  not  report  having  experienced  issues  in  relation  to 
enforcement of Directive 2002/15/EC. Some Member States shared specific issues they face 
at the national level.  

Like  in  the  previous  reporting  period,  Cyprus  reported  difficulties  in  implementing  the 
relevant  legislation  in  situations when  drivers frequently  change  vehicles. These difficulties 
can occur, for instance, when a driver uses different generations of tachographs in each of the 
driven vehicle, or when he or she drives both vehicles covered  by regulations requiring the 
use  of  tachographs  and  vehicles  benefitting  from  an  exemption  from  the  obligation  to  use 
tachographs.  In  order  to  control  these  cases  more  effectively,  Cyprus  suggested  that 
undertakings should keep detailed records of data from both tachograph and other documents 
on the working time in line with Article 9 of Directive 2002/15/EC. 

The  Czech  authorities  informed  that  there  are  still  difficulties  when  checking  compliance 
with the provisions of Directive 2002/15/EC in the situation where drivers are employed by 
more than one employer and where those undertakings are not generally aware of themselves. 
The  same  problem  was  reported  by  Austria.  Another  problem  reported  by  the  Czech 
authorities concerned undertakings operating regular passenger transport services or lines of 
up to 50 kilometers, which are not obliged to check records of working time performed for 
another  transport  undertaking.  The  activities  of  public  transport  and  bus  drivers  are  not 
recorded  by  any  technical  equipment,  such  as  the  digital  tachograph.  This  precludes  the 
possibility  of  checking  the  working  and  rest  times  of  these  drivers  on  the  basis  of  digitally 
recorded data, including the possibility of verifying timesheets worked for another employer. 
As  reported,  these  cases  of  working  for  two  employers  without  respecting  rest  periods  are 
difficult to prove. 

Several Member States reported a lack of human resources to ensure adequate enforcement of 
their  national  regulations  under  Directive  2002/15/EC.  In  particular,  it  was  reported  that 
monitoring  compliance  with  the  provisions  of  this  Directive  requires  considerable 
investigative effort on the part of competent authorities. This is particularly true in relation to 
the requirement of compensation for weekly working time. The Czech Authorities raised the 
issue of competitiveness, because Directive 2002/15/EC sets weekly working time for mobile 
workers  at  an  average  of  48  hours,  which  is  significantly  higher  than  the  weekly  working 
time set out by the Czech Labour Code, which is 40 hours per week. To remain competitive, 
Czech  carriers  deliberately  exceed  the  weekly  working  time  limits  for  drivers  driving 
international  trucks.  Self-employed  drivers,  whose  working  hours  are  regulated  by  another 
act,  which  is  not  subject  to  State  Labour  Inspection  Office  control,  continue  to  enjoy  a 
competitive advantage and allow such drivers to work 48 hours per week.  

27 

 
 
The  Swedish  authorities  commented  that  the  infringements  in  working  time  legislation  are 
not due to the legislation itself but to the inspection activities, and stressed the importance of 
cooperation and dialogue between authorities and social partners.    

From the Italian perspective, entering into agreements with trade union by many companies 
in  the  sector  allowed  to  adapt  their  work  organisation  to  the  working  time  rules.  The 
authorities also highlighted the importance of adopting a dedicated IT application to facilitate 
control  activities, as  it is now possible to  separately  monitor infringements  by the driver of 
road traffic rules and national rules transposing the European Directive, as well as to assess 
on a monthly basis the driver’s overall working time and the consequences in terms of salary 
and social security and insurance contributions due to the worker. 

19. Stakeholders' views on implementation of Directive 2002/15/EC in Member States 

Only  10  Member  States39  clearly  indicated  that  social  partners  had  been  consulted  for  the 
purpose of this reporting exercise. This number is slightly lower compared to the last report 
with  12  Member  States.  Germany,  Poland  and  Portugal  quoted  a  significant  number  of 
organisations,  which  were  consulted.  In  all  Member  States,  this  consultation  consisted  in 
getting  the  views  of  representatives  of  employers  and  trade  unions.  The  views  of  social 
partners were not always reflected in a separate section or paragraph, but rather incorporated 
throughout  the  document,  indistinctly  from  the  views  of  national  authorities.  However,  the 
feedback  from  social  partners  was  an  important  element  of  the  report  from  seven  Member 
States40.  

Therefore,  opinions  from  social  partners  cannot  be  analysed  as  they  do  not  constitute  a 
representative  sample.  The  Commission  would  like  to  remind  Member  States  that  Article 
13(1) of Directive 2002/15/EC requires them to include the views of both sides of industry as 
part  of  this  reporting  exercise.  The  received  feedback  from  national  social  partners  can  be 
found in the table below. 

Feedback from national social partners 

 

In  France,  the  social  partners  reiterated  their  wish  for  a  high-level  of  European  social  legislation  in 

order to guarantee healthy and fair competitive conditions for companies and to ensure quality jobs in 

the  sector.  The  trade  unions  remain  committed  to  the  national  legislation  on  working  time,  as  it  is 

generally more favourable to workers than European legislation. They do not want to see any changes 

to  the  latter  that  would  jeopardise  the  balance  between  the  interests  of  drivers  and  the  needs  of 

companies. They very much expect to see a strengthening of the control policy to better guarantee the 

application of the existing rules. The professional organisations also supported measures to improve the 

organisation of drivers' work. 

 

In  Germany,  only  one  trade  union  recommended  the  provision  of  adequate  technical  and  human 

resources, including instruments of financial penalties, for police and control authorities. The issue of 

working time other than driving time was also pointed out, especially with regard to the start-up time of 

39 Cyprus, Estonia, Finland, France, Germany, Italy, Poland, Portugal, Slovakia, and Sweden. Austria informed 
that draft report was discussed in the Parliament publicly available on the Labour Inspectorate website.   
40 France, Germany, Poland, Italy, Slovakia, Portugal, and Sweden.  

28 

 
 
                                                           
mobile workers if vehicles are not available at the driver’s residence. It was suggested that supervisory 

authorities should obtain a reliable picture of how often Article 12 of Regulation (EC) No 561/2006 is 

used to enforce compliance with working times.  

 

In Poland, the Chamber of Commerce for Motor Transport and Forwarding commented on the content 

of  the  national  report,  expressing  doubts  regarding  the  number  of  drivers  inspected  by  the  National 

Labour  Inspectorate,  the  number  of  infringements  detected  by  the  General  Inspectorate  of  Road 

Transport,  and  the  lack  of  information  on  inspections  of  foreign  haulers.  The  Polish  authorities 

explained both inspectorates confirmed the  accuracy of the data provided, the number of inspections 

carried out and the infringements detected. 

  One  Slovakian  trade  union  recommended  that  the  EU  should  introduce  a  common  legislative 

harmonisation  of  the  way  sanctions  are  categorised  and  on  the  level  of  penalties  for  serious 

infringements,  since  this  would  reduce  or  eliminate  significant  differences  in  the  type  and  level  of 

penalties imposed during inspections between countries.  

  Portugal, feedback from the industry was generally positive. No comments were received from trade 

unions.  

 

In  Sweden,  feedback  from  the  industry  was  also  generally  positive.  In  particular,  the  lack  of  direct 

sanctions  and  the  fact  that  employers  and  self-employed  workers  have  the  possibility  to  adapt  their 

behaviour  to  the  working  time  regulations  were  appreciated.  It  was  also  reported  that  although 

shortcomings had been identified during the inspection activities, no action plan or follow-up had been 

found to address these shortcomings.  

  The  Italian  employers’  associations  were  generally  positive  about  collective  agreements  that  were 

concluded by most Italian companies with the trade unions. It was pointed out that the flexibility of the 

Directive has been decisive for the preservation of road transport undertakings, even in the situation of 

the COVID-19 crisis. In contrast, the flexibility aspect of the system is no longer fully accepted by the 

trade unions, which considered that the current context has changed profoundly since 2008 and needs 

the  reassessment.  Trade  unions  also  called  for  increased  checks  both  at  the  roadside  and  at  the 

premises. 

Some  employers’  associations  also  stressed  the  need  for  strengthen  European  action,  making  the 

following proposals: 

 1) Creation of a special status for “mobile workers” operating within the EU, including professional 

drivers  engaged  in  international  activities.  This  special  regime  should  entail  a  minimum  wage  at 

European level and a uniform social security; 

2)  Establishment  of  a  mandatory,  nominative  and  transparent  European  register  of  drivers  with  a 

harmonised social role (remuneration and social security); 

3) Introduction of a derogation from Regulation (EC) No 883/2004 stating, in the case of the posting of 

29 

 
 
workers  performing  mobile  road  transport  activities,  the  application  of  a  single  European  social 

security system;  

4) Establishment of a European Road Transport Agency. 

30 

 
 
 
 
 
 
20. Statistics on working days checked at the roadside and premises in 2019-2020 

MS 

AT 

BE 

BG 

HR 

CY 

CZ 

DK 

EE 

FI 

FR 

DE 

EL 

HU 

IE 

IT 

LV 

LT 

LU 

MT 

NL 

PL 

PT 

RO 

SK 

SI 

ES 

SE 

TOTAL 

Minimum 
checks 

1.409.760 
1.860.857 
3.568.986 
768.211 
140.994 
1.470.374 
660.000 
250.800 
1.087.535 
6.899.244 
9.348.198 
3.492.465 
3.338.701 
3.890.937 
17.394.774 
441.986 
924.240 
169.128 
2.856 
1.809.812 
7.160.358 
772.715 
1.668.634 
504.000 
432.945 
6.021.284 
1.003.200 
76.492.994 

Total 
number 
2019-2020 

3.778.471 
1.950.531 
3.695.276 
836.128 
175.171 
1.976.676 
823.750 
265.879 
1.697.655 
16.222.034 
21.555.057 
2.779.225 
2.515.902 
587.859 
8.638.031 
1.319.678 
1.051.196 
164.289 
224 
885.196 
8.250.569 
1.620.756 
15.508.290 
545.675 
643.563 
9.954.539 
1.437.935 
108.879.555 

At the 
roadside 

At the 
premises 

3.050.677 
1.603.102 
1.753.420 
553.853 
58.305 
1.270.930 
526.620 
97.092 
1.123.527 
13.608.973 
17.741.619 
337.725 
1.894.032 
103.657 
7.181.012 
535.540 
391.741 
106.652 
224 
758.814 
4.377.935 
1.181.202 
7.920.369 
203.945 
342.538 
6.938.169 
919.937 
74.581.610 

727.794 
347.429 
1.941.856 
282.275 
116.866 
705.746 
297.130 
168.787 
574.128 
2.613.061 
3.813.438 
2.441.500 
621.870 
484.202 
1.457.019 
784.138 
659.455 
57.637 
- 
126.382 
3.872.634 
439.554 
7.587.921 
341.730 
301.025 
3.016.370 
517.998 
34.297.945 

Min. checks 
required in 
% at 
roadside 
81% 
82% 
47% 
66% 
33% 
64% 
64% 
37% 
66% 
84% 
82% 
12% 
75% 
18% 
83% 
41% 
37% 
65% 
100% 
86% 
53% 
73% 
51% 
37% 
53% 
70% 
64% 
60% 

Min. checks 
required in 
% at 
premises 
19% 
18% 
53% 
34% 
67% 
36% 
36% 
63% 
34% 
16% 
18% 
88% 
25% 
82% 
17% 
59% 
63% 
35% 
- 
14% 
47% 
27% 
49% 
63% 
47% 
30% 
36% 
40% 

Working 
days 
checked  
in % 
8,0% 
3,1% 
6,2% 
3,3% 
3,7% 
3,9% 
3,7% 
3,2% 
4,7% 
7,1% 
6,9% 
2,4% 
2,3% 
0,5% 
3,0% 
9,0% 
3,4% 
2,9% 
0,2% 
1,5% 
3,5% 
6,3% 
15,9% 
3,2% 
4,5% 
5,0% 
2,2% 
4,5% 

21. Statistics on number of working days checked at roadside by country of registration 
of the vehicle 

MS 

AT 
BE 
BG 
HR 
CY 
CZ 

National 
vehicles 
952.313 
575.527 
947.117 
346.625 
58.305 
636.268 

Non-
national 
2.052.794 
907.509 
439.233 
57.952 
- 
580.577 

31 

Third 
countries 
45.570 
120.066 
367.070 
149.276 
- 
54.085 

Total 

3.050.677 
1.603.102 
1.753.420 
553.853 
58.305 
1.270.930 

 
 
 
 
 
 
DK 
EE 
FI 
FR 
DE 
EL 
HU 
IE 
IT 
LV 
LT 
LU 
MT 
NL 
PL 
PT 
RO 
SK 
SI 
ES 
SE 
TOTAL 

374.295 
76.002 
921.581 
4.514.792 
8.025.111 
282.964 
839.328 
88.785 
5.768.989 
224.565 
290.989 
31.218 
84 
296.206 
2.219.921 
1.123.218 
6.544.145 
90.292 
79.579 
6.186.408 
483.665 
41.978.292 

146.805 
18.130 
115.109 
8.835.906 
8.862.461 
36.509 
843.836 
14.741 
1.284.741 
200.762 
59.970 
73.350 
140 
433.231 
1.003.925 
57.893 
922.460 
99.550 
172.709 
723.623 
412.712 
28.356.628 

5.520 
2.960 
86.837 
258.274 
854.047 
18.252 
210.868 
131 
127.282 
110.213 
40.782 
2.084 
- 
29.377 
1.154.089 
91 
453.764 
14.103 
90.250 
28.138 
23.560 
4.246.689 

526.620 
97.092 
1.123.527 
13.608.973 
17.741.619 
337.725 
1.894.032 
103.657 
7.181.012 
535.540 
391.741 
106.652 
224 
758.814 
4.377.935 
1.181.202 
7.920.369 
203.945 
342.538 
6.938.169 
919.937 
74.581.610 

22.  Statistics  on  checks  at  roadside  by  the  number  of  drivers  checked,  by  country  of 
registration and by type of carriage 

MS 

AT 

BE 

BG 

HR 

CY 

CZ 

DK 

EE 

FI 

FR 

DE 

EL 

HU 

IE 

IT 

LV 

LT 

LU 

Total 
drivers 

181.226 
148.684 
102.840 
22.059 
3.799 
66.953 
39.009 
7.880 
39.432 
547.638 
903.949 
87.402 
67.644 
4.335 
592.210 
24.441 
14.928 
6.667 

Nationals 

Non-
nationals 

3rd 
countries 

Carriage of 
passengers 

Carriage of 
goods 

57.426 
55.876 
63.408 
13.999 
3.799 
37.099 
27.725 
6.423 
31.970 
206.093 
424.802 
72.032 
29.976 
3.705 
493.773 
11.255 
11.273 
1.917 

117.489 
82.121 
11.317 
2.256 
0,00% 
26.684 
10.875 
1.202 
4.246 
331.699 
434.089 
10.931 
30.137 
624 
89.315 
8.396 
2.239 
4.609 

32 

6.311 
10.687 
28.115 
5.804 
0 
3.170 
409 
255 
3.216 
9.846 
45.058 
4.439 
7.531 
6 
9.122 
4.790 
1.416 
141 

1.656 
5.519 
14.107 
2.582 
769 
3.052 
7.508 
194 
999 
35.601 
26.495 
64.110 
895 
4.031 
25.988 
585 
773 
225 

179.570 
143.165 
88.733 
19.477 
3.030 
63.901 
31.501 
7.686 
38.433 
512.037 
877.454 
23.292 
66.749 
304 
566.222 
23.856 
14.155 
6.442 

 
 
 
 
MT 

NL 

PL 

PT 

RO 

SK 

SI 

ES 

SE 

TOTAL 

8 
26.166 
371.509 
40.194 
526.743 
10.599 
17.224 
431.304 
38.402 
4.323.245 

3 
10.214 
220.866 
37.986 
438.070 
4.903 
5.881 
396.589 
19.984 
2.687.047 

5 
14.939 
69.693 
2.193 
56.927 
4.772 
7.362 
32.584 
17.252 
1.373.956 

0 
1.013 
80.950 
15 
31.746 
924 
3.702 
2.131 
1.166 
261.963 

- 
466 
78.154 
3.800 
76.311 
621 
1.904 
1.904 
472 
358.721 

8 
25.700 
293.355 
36.394 
450.432 
9.978 
15.041 
402.225 
37.930 
3.937.070 

23.  Statistics  on  checks  at  roadside  by  the  number  of  vehicles  stopped  by  country  of 
registration and type of tachograph 

3rd 
country 

Analog. 
tachogr. 

% analog. 

MS 

AT 

BE 

BG 

HR 

CY 

CZ 

DK 

EE 

FI 

FR 

DE 

EL 

HU 

IE 

IT 

LV 

LT 

LU 

MT 

NL 

PL 

PT 

RO 

SK 

SI 

ES 

SE 

Total 

National 

181.226 

115.410 

102.840 

21.509 

3.799 

69.433 

32.480 

7.880 

39.432 

57.426 

46.472 

81.539 

13.924 

3.799 

36.667 

20.427 

6.423 

31.939 

Non-
national 

117.489 

60.815 

7.507 

2.146 

- 

29.816 

11.715 

1.202 

4.441 

537.082 

205.075 

322.470 

87.402 

65.657 

4.335 

70.443 

27.884 

3.705 

11.574 

30.581 

624 

592.158 

493.730 

89.307 

24.430 

11.255 

8.451 

- 

- 

- 

6.667 

1.915 

4.615 

8 

3 

26.166 

10.214 

332.765 

196.055 

40.192 

38.005 

5 

14.939 

62.341 

2.168 

6.311 

8.123 

13.794 

5.439 

- 

2.950 

338 

255 

3.052 

9.537 

5.385 

7.192 

6 

9.121 

4.724 

- 

137 

- 

7228 

4113 

24279 

- 

2663 

9331 

1350 

2209 

5.855 

80562 

46893 

49296 

8882 

716 

145613 

5726 

- 

572 

2 

1.013 

2503,976 

74.369 

19 

63282 

11950 

810.066 

385.163 

381.721 

43.182 

519.464 

432.146 

55.397 

31.921 

307540 

10.769 

13.655 

4.853 

6.392 

431.304 

394.037 

36.588 

19.715 

4.992 

3.698 

34.879 

16.126 

924 

3.565 

2.388 

747 

576 

1648 

38584 

2098 

4% 

4% 

24% 

- 

70% 

13% 

4% 

28% 

15% 

15% 

6% 

56% 

14% 

17% 

25% 

23% 

- 

9% 

25% 

10% 

19% 

30% 

59% 

5% 

12% 

9% 

6% 

Digital 
tachogr. 

170863 

88251 

78561 

- 

1135 

59521 

31130 

5601 

28.204 

380542 

761501 

38106 

56775 

3619 

446369 

18704 

- 

6095 

6 

22391,9 

227723 

28242 

209684 

10193 

12002 

306760 

34490 

% digital 

94% 

76% 

76% 

0% 

30% 

86% 

96% 

71% 

72% 

71% 

94% 

44% 

86% 

83% 

75% 

77% 

- 

91% 

75% 

86% 

68% 

70% 

40% 

95% 

88% 

71% 

94% 

74% 

Smart 
tacho 

3135 

23046 

- 

11 

1 

581 

- 

70 

5.373 

75978 

1672 

- 

- 

- 

176 

- 

- 

- 

- 

1270,128 

1.727 

- 

2240 

- 

5 

- 

- 

% smart 

2% 

20% 

- 

- 

- 

1% 

- 

1% 

14% 

14% 

- 

- 

- 

- 

- 

- 

- 

- 

- 

5% 

1% 

- 

- 

- 

- 

- 

- 

115.285 

3% 

TOTAL 

4.112.717 

2.599.206 

1.279.019 

234.492 

831.485 

20% 

3.039.954 

33 

 
 
 
 
 
24. Statistics on checks at premises by the number of drivers, undertakings and working 
days checked 

MS 

AT 
BE 
BG 
HR 
CY 
CZ 
DK 
EE 
FI 
FR 
DE 
EL 
HU 
IE 
IT 
LV 
LT 
LU 
MT 
NL 
PL 
PT 
RO 
SK 
SI 
ES 
SE 
TOTAL 

Number of 
drivers  
2019-2020 
11.469 
16.765 
96.751 
1.717 
1.349 
6.142 
22.487 
3.022 
10.658 
61.499 
56.915 
9.766 
4.409 
3.771 
15.505 
2.969 
17.468 
2.015 
- 
4.358 
29.286 
4.523 
7.366 
5.237 
1.674 
93.602 
9.220 
499.943 

Number of 
undertakings 
2019-2020 
1.297 
3.529 
7.643 
271 
554 
775 
2.366 
247 
1.810 
3.490 
5.057 
1.798 
955 
340 
4.720 
361 
846 
122 
- 
237 
3.543 
831 
1.262 
640 
327 
14.919 
360 
58.300 

At the 
premises 

727.794 
347.429 
1.941.856 
282.275 
116.866 
705.746 
297.130 
168.787 
574.128 
2.613.061 
3.813.438 
2.441.500 
621.870 
484.202 
1.457.019 
784.138 
659.455 
57.637 
- 
126.382 
3.872.634 
439.554 
7.587.921 
341.730 
301.025 
3.016.370 
517.998 
34.297.945 

25. Statistic on types of offences at roadside 

MS 

AT 

BE 

BG 

HR 

CY 

CZ 

DK 

Driving 
time 

42.935 
1.701 
236 
743 
17 
3.386 
167 

Breaks 

Rest 
periods 

76.245 
1.613 
311 
1.311 
325 
6.433 
128 

60.613 
4.075 
1.348 
3.420 
90 
7.779 
880 

Record. 
equipm. 
incorrect 
function. 
627 
538 
219 
33 
172 
504 
910 

Record. 
equipm. 
misuse/ 
manipul. 
2843 
989 
169 
1288 
0 
365 
1071 

Lack/avail. 
of records 
for other 
work 
20.772 
75 
689 
297 
8 
1.060 
48 

Total 
number of 
offenses 
2019-2020 
245.368 
9.128 
3.611 
8.930 
648 
41.435 
3.209 

28 days 
record 
sheets 

41.333 
137 
639 
1.838 
36 
21.908 
5 

34 

 
 
 
 
 
EE 

FI 

FR 

DE 

EL 

HU 

IE 

IT 

LV 

LT 

LU 

MT 

NL 

PL 

PT 

RO 

SK 

SI 

ES 

SE 

TOTAL 

223 
516 
32.871 
61.773 
7.797 
246 
118 
14.474 
204 
568 
1.106 
10 
1.586 
18.885 
5.805 
6.470 
987 
2.027 
32.373 
6.040 
243.264 

586 
998 
4.397 
42.806 
6.076 
834 
1.618 
11.644 
213 
61 
927 
1 
1.549 
20.484 
3.611 
5.742 
2.476 
1.306 
16.479 
6.467 
214.641 

655 
524 
43.696 
62.123 
12.986 
1.139 
929 
18.472 
448 
557 
755 
7 
2.397 
43.996 
6.366 
18.118 
2.130 
2.575 
55.601 
7.334 
359.013 

731 
- 
10 
99.345 
5.694 
- 
886 
40.784 
1.070 
656 
20 
1 
96 
1.286 
4.195 
2.688 
699 
304 
14.992 
175 
239.528 

338 
15 
13.941 
82469 
2088 
211 
812 
4823 
31 
388 
12 
2 
663 
2792 
2507 
2426 
366 
822 
5485 
263 
123457 

1287 
13 
1.201 
2670 
2775 
389 
2 
1420 
58 
142 
3 
- 
2044 
16688 
4751 
13571 
106 
997 
533 
102 
55477 

51 
- 
- 
68.248 
5.728 
- 
- 
443 
- 
176 
250 
7 
- 
21.851 
1.756 
635 
220 
1.179 
7 
78 
123.578 

3.871 
2.066 
96.116 
419.434 
43.144 
2.819 
4.365 
92.060 
2.024 
2.548 
3.073 
28 
8.335 
125.982 
28.991 
49.650 
6.984 
9.210 
125.470 
20.459 
1.358.958 

26. Statistics on types of offences at premises 

MS 

AT 

BE 

BG 

HR 

CY 

CZ 

DK 

EE 

FI 

FR 

DE 

EL 

HU 

IE 

IT 

LV 

LT 

LU 

MT 

NL 

Driving 
time 

731 
2.727 
184 
239 
668 
1.270 
122 
331 
5.941 
1.465 
40.909 
478 
356 
92 
3.833 
- 
2.250 
911 
- 
1.277 

Breaks 

1.666 
3.356 
18 
565 
6.401 
2.120 
1.224 
369 
21.118 
609 
122.354 
99 
431 
4.543 
7.085 
- 
954 
1.411 
- 
4.469 

Rest 
periods 

1.607 
8.768 
218 
1.140 
5.852 
2.878 
675 
1.041 
14.502 
4.586 
53.155 
342 
759 
2.219 
6.809 
- 
2.145 
1.989 
- 
2.176 

Recording 
equipment 
incorrect 
function. 
539 
- 
85 
- 
753 
206 
4 
- 
125 
7 
13.330 
- 
12 
370 
481 
- 
23 
5 
- 
- 

Offenses 
for driving 
time 
records 
2 
380 
285 
3 
326 
4.820 
216 
20 
435 
1.501 
7.946 
3 
3.248 
365 
42.138 
- 
1.379 
11 
- 
6.366 

35 

Recording 
equipment 
manipul. 

18 
79 
39 
185 
2 
362 
- 
- 
734 
2.081 
204 
- 
17 
- 
585 
- 
365 
9 
- 
1.567 

Lack/avail. 
of records 
for other 
work 
- 
- 
24 
232 
46 
93 
- 
2 
150 
1 
38.695 
2 
457 
- 
420 
- 
176 
53 
- 
2 

Total 
number of 
offenses 
2019-2020 
4.563 
15.310 
853 
2.364 
14.048 
11.749 
2.241 
1.763 
43.005 
10.250 
276.593 
924 
5.280 
7.589 
61.351 
- 
7.292 
4.389 
- 
15.857 

 
 
 
 
PL 

PT 

RO 

SK 

SI 

ES 

SE 

TOTAL 

10.266 
59 
382 
2.417 
412 
5.290 
1.015 
83.625 

21.805 
32 
458 
4.276 
515 
2.987 
3.086 
211.951 

25.059 
78 
1.477 
4.866 
750 
7.577 
3.417 
154.085 

272.575 
3 
44 
358 
197 
8.086 
1.721 
352.428 

127 
- 
12 
8 
17 
561 
276 
16.941 

3.040 
- 
215 
81 
74 
328 
- 
9.985 

17.119 
- 
- 
106 
26 
137 
2.899 
60.640 

349.991 
172 
2.588 
12.112 
1.991 
24.966 
12.414 
889.655 

36