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 2021-2022 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 (32nd report from the Commission on the implementation of the social legislation relating to road transport)
Date: 2024-09-13
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, 13.9.2024  SWD(2024) 215 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 2021-2022 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 (32nd report from the Commission on the implementation of the social legislation relating to road transport)     {COM(2024) 405 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, also known as the Tachograph Regulation, 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 
administrative burden and making fraud to the tachograph more difficult. A smart tachograph 

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 Regulation (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 

 
 
 
 
has to be fitted in vehicles registered for the first time as of 15 June 20193. A second version 
of  the  smart  tachograph  has  advanced  communication  features  including  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.  

Mobility  Package  I5  amended  rules  on  breaks,  driving  times,  rest  periods  and  tachograph 
requirements  set  out  by  Regulation  (EC)  No  561/2006,  Regulation  (EU)  165/2014  and 
Directive  2006/22/EC  as  well  as  introduced  specific  rules  on  posting  of drivers  in  the  road 
transport  sector6.  The  new  rules  under  Regulations  (EC)  No  561/2006  and  (EU)  165/2014 
started applying from 20 August 2020 and the information on their implementation is provided 
in  the  current  report,  however  some  new  types  of  infringements,  such  as  the  breach  of 
organising the work to allow the driver to return home, are not included in this 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. 

3 This applies to the first version of smart tachographs, while the second version of smart tachographs has to be 
fitted in all newly registered vehicles as of 21 August 2023.  
4 Pursuant to Article 6 of Directive 2006/22/EC, as amended 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) 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). 
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). 

2 

 
 
 
 
2. Checks 

The total number of working days checked in the EU increased by 3% in 2021-2022 compared 
to the period of 2019-2020. This reverses a continuous decreasing trend which was observed 
since  2011-2012.  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: Austria  (7.7%),  Bulgaria  (7.7%),  Finland  (5.6%),  Germany  (6.5%), 
Latvia (5.9%), Portugal  (8.4%) and Romania (21.3%). This is the same number of Member 
States as in the last reporting period7. Among these seven Member States, Bulgaria, Finland, 
Portugal and Romania increased the number of working days checked, while other countries 
experienced decrease of this number.   

Six  Member  States  did  not  meet  the  minimum  threshold  of  3%,  namely  Cyprus  (2.4%), 
Hungary (1,5%), Ireland (0.7%), Lithuania (2.7%), Malta (0.5%), and Slovenia (2.4%). This is 
the same number of countries as in the previous reporting period. Great increases in the number 
of  working  days  checked  were  observed  in  Malta  (+450%8)  and  the  Netherlands  (+185%), 
while the decreases of working days checked is most visible in Slovenia (-48%), France (-45%) 
and Hungary (-39%).     

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  eight Member States have the required balanced share between working 
days checked at the premises and at the roadside: Croatia (51% of working days checked at the 
premises), Cyprus (64%), Estonia (55%), Greece (68%), Malta (50%), the Netherlands (69%), 
Slovakia (57%) and Sweden (53%). Yet, this is an increase 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 47% in 2021-
2022, which is an increasing trend compared to 40% in 2019-2020, 27% in 2017-2018, 26% in 
2015-2016,  23%  in  2013-2014  and  18%  in  2009-2010. The  most  significant  improvements 
were reported by Croatia (from 34% to 51%), Malta (from 0% to 50%), the Netherlands (from 
14% to 69%) and Sweden (from 36% to 53%).   

Ireland, Latvia and Slovenia are the only Member States which have not met the threshold for 
roadside checks9.  

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  increased  from  54,679  in  2019-2020  to  60,040.  The  total 
number  of  enforcement  officers  trained  to  analyse  the  digital  tachograph  has  continued  to 
slightly  decrease  from  20,058  in  2019-2020  to  17,081  in  2021-2022.  Also,  the  units  of 

7 However, France (7.1% in 2019-2020 against 3.8% in 2021-2022) was replaced by Finland (4.7% against 5.6% 
in 2021-2022).  
8 It is to be noted that Malta has still not met the threshold of 3% of working days.    
9 Greece and Ireland in 2019-2020.  

3 

 
 
 
equipment  provided  to  control  officers  to  analyse  the  tachograph  decreased  from  13,067  in 
2019-2020 to 8,336 in 2021-2022. 

Table 1: Overview of national enforcement capacity in 2021-2022 per Member State 

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 

Control 
officers 
involved in 
checks 

Control officers trained to 
analyse the digital 
tachograph 

Units of equipment provided to 
control officers to analyse the 
tachograph 

1100 

3833 

398 
244 
133 
1330 
97 
32 
340 

1310 
14761 
3614 
450 
18 
18038 
25 
45 
17 
1 
200 
1116 
11431 
366 
31 
75 
498 
537 
60040 

1100 

3598 

360 
36 
8 
1330 
117 
32 
350 

1310 
2980 
921 
400 
18 
1433 
25 
45 
17 
1 
300 
966 
490 
366 
33 
40 
386 
419 
17081 

350 

132 

324 
36 
14 
753 
96 
18 
134 

1209 
2167 
288 
300 
18 
938 
13 
28 
10 
1 
65 
263 
240 
0 
33 
0 
445 
461 
8336 

4. Roadside checks 

The total number of working days checked at the roadside was 72,395,053 which is a decrease 
compared to 74,581,610 working days checked at the roadside in the previous reporting period. 
In general, 29% of vehicles checked at the roadside are from another EU or EEA country or 
from  Switzerland,  which  is  a  slight  decrease  since  2019-2020  (31%).  However,  in  some 
Member States the percentage of checked vehicles from these countries constitutes more than 
half: namely Austria (66%), Belgium (53%), France (57%), Luxembourg (66%), Malta (77%) 
and the Netherlands (56%). These are the same  Member States as named in  the 2019-2020 
report. The geographic location and volume of transit operations may, in certain Member States 

4 

 
 
 
 
play a factor. 7% of vehicles checked at the roadside are from third countries (6% in 2019-
2020). Member States whose share of checking vehicles registered in a third country was the 
largest are Bulgaria (36%), Croatia (30%), Poland (21%), and Slovenia (28%)10. A complete 
overview per Member State can be found in Table 2 below.  

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

MS 

Nationals 

Non- nationals including 
EU/ EEA and CH 

3rd nationals 

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 

29.9% 
40.3% 
51.3% 
61.2% 
98.7% 
51.0% 
66.9% 
75.9% 
79.4% 
41.4% 
45.4% 
77.2% 
57.2% 
89.6% 
81.0% 
49.2% 
71.3% 
32.1% 
22.7% 
39.4% 
54.3% 
95.4% 
80.1% 
41.3% 
34.7% 
91.8% 
51.4% 
64% 

66.2% 
52.7% 
12.7% 
9.0% 
1.3% 
43.9% 
32.2% 
19.9% 
11.4% 
56.6% 
48.9% 
12.9% 
33.5% 
10.4% 
17.2% 
36.9% 
12.2% 
65.8% 
77.3% 
55.8% 
24.2% 
4.5% 
12.5% 
50.2% 
37.2% 
7.5% 
44.8% 
29% 

3.82% 
7.04% 
36.01% 
29.86% 
0.00% 
5.12% 
0.82% 
4.16% 
9.16% 
1.99% 
5.69% 
9.87% 
9.22% 
0.04% 
1.76% 
13.92% 
16.47% 
2.12% 
0.00% 
4.74% 
21.46% 
0.02% 
7.40% 
8.48% 
28.05% 
0.69% 
3.83% 
7% 

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. 

10 Bulgaria (13%), Croatia (25%), Poland (22%) and Slovenia (26%) in the previous reporting period 2019-2020. 

5 

 
 
 
 
Compared to the last report, the share of vehicles checked at the roadside that were equipped 
with the digital tachograph increased from 74% to the level of 83%. There is therefore still no 
base to raise the threshold of minimum checks to 4% for the time being. The highest share of 
digital tachographs (more than 80%) was found during roadside checks in eighteen11 Member 
States:  Denmark  (99%),  Sweden  and  Slovakia  (97%),  Austria  (94%),  Hungary  (93%), 
Germany  (92%12),  Luxembourg  (92%),  Ireland  (90%),  France  (87%),  Malta  and  Slovenia 
(86%),  Czech  Republic  and  Latvia  (85%),  Italy  (83%),  the  Netherlands  and  Poland  (82%), 
Romania (81%). Lithuania informed that due to a technical error, full data was not available 
and 100% was attributed to digital tachographs. The number of Member States meeting the 
share of 90% digital tachographs has increased from six to eight since the last reporting period. 
In  contrast,  the  lowest  percentage  of  digital  tachograph  was  reported  in  Greece  (53%)  and 
Croatia (68%). Table 3 below provides a full overview. 

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

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 

Analogue 
tachograph 

% 

analogue 

Digital 
tachograph 

% 

Smart tacho  % 

digital 

smart 

4926 
4113 
17258 
6435 
661 
6357 
431 
2056 
6059 
25739 
46297 
48888 
3916 
656 
87178 
2848 
0 
802 
3 
2381 
40811 
10872 
78728 
428 
2537 
30942 

3% 
4% 
19% 
27% 
20% 
10% 
1% 
19% 
15% 
13% 
6% 
47% 
7% 
10% 
17% 
15% 
0% 
8% 
14% 
9% 
13% 
24% 
18% 
3% 
12% 
7% 

156637 
88251 
73428 
16420 
2588 
52851 
30885 
8494 
29454 
168997 
656542 
55193 
51092 
6216 
435248 
16487 
13393 
8713 
19 
22056 
260546 
34234 
359379 
12301 
18178 
343299 

94% 
76% 
80% 
68% 
79% 
85% 
99% 
79% 
72% 
87% 
92% 
53% 
93% 
90% 
83% 
85% 
100% 
92% 
86% 
82% 
82% 
76% 
81% 
97% 
86% 
73% 

4739 
23046 
1290 
1305 
18 
3248 
0 
229 
5450 
36 
10280 
0 
74 
0 
3012 
0 
0 
0 
0 
2437 
13,305 
0 
8259 
0 
395 
0 

3% 
20% 
1% 
5% 
1% 
5% 
0% 
2% 
13% 
0% 
1% 
0% 
0% 
0% 
1% 
0% 
% 
0% 
0% 
9% 
4% 
0% 
2% 
0% 
2% 
0% 

11 Eleven Member States in the previous reporting period.  
12 Germany reported 94% in the previous reporting period.  

6 

 
 
 
SE 
TOTAL 

1006 
432,328 

3% 
12% 

38236 
2,959,137 

97% 
83% 

3 
77126 

0% 
2% 

6. Checks at the premises 

The total number of working days checked at premises was 39,339,243 which is an increase 
compared to 34,297,945 working days checked at premises in the previous reporting period.  

Two  Member  States  which  imported  an  impressive  increase  in  the  share  of  working  days 
checked at the premises compared to the previous reporting period are the Netherlands (from 
14% to 69%) and Slovenia (from 47% to 89%). Figure 1 presents the share of working days 
checked at the premises from 2015.  

Figure 1: Share of working days checked at the premises in 2015-2022 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

e
g
a
r
e
v
A
U
E

2015-2016

2017-2018

2019-2020

2021-2022

In total, Member States checked 582,218 drivers during 2021-20220 (against around 499,943 
drivers during 2019-2020), which is an increase from previous periods, reversing a decreasing 
trend compared to the previous periods. However, Member States where the number of drivers 
checked at the premises decreased more than 40% are: Bulgaria (-71%) and Luxembourg (-
41%). Two  countries,  the  Netherlands  and  Romania,  reported  an  impressive  increase  in  the 
number of drivers checked at the premises (more than 800%). 

In this reporting period, 84,128 transport undertakings were checked at the premises (against 
58,300 transport undertakings during 2019-2020), which is a 44% increase compared to the 
previous period. Nevertheless, some Member States reported more than a 40% decrease in the 
number of undertakings checked at the premises, namely Cyprus (-42%) and Luxembourg (-
57%).  

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 13% in 2021-2022 (12% 
share in 2019-2020, 11% share in 2017-2018, 10% share in 2015-2016, 9% in 2013-2014 and 
7% in 2011-2013).  

7 

 
 
 
 
 
7. Offences – detection rate 

The average detection offence rate, which is calculated based on 100 working days checked at 
premises and roadside checks, increased from 2.1 in 2019-2020 to 2.7 in the current reporting 
period.  

Significant  disparities  continue  to  exist  between  Member  States.  Four  Member  States  are 
marking the total lowest offence rate (per 100 working days) in the EU: 0.08 in Latvia, 0.17 in 
Bulgaria,  0,18  in  Romania  and  0.46  in  Denmark.  At  the  same  time,  the  following  Member 
States have very high offence rates: 12.40 in Cyprus, 6.26 in Austria, 9.57 in Poland.  

A significant increase in the offence rate can be observed in Cyprus (from 8.39 to 12.40), the 
Netherlands (from 2.73 to 11.80) and Poland (from 5.77 to 9.57), whereas a significant drop 
was reported by Malta (from 12.50 to 2.44). The table in Figure 2 provides an overview of the 
development of the offence rate in EU Member States since 2015. 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 standard13, 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.  

Figure 2: Total offence detection rate at the roadside and premises checked between 2015-2022 

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

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

2021-2022 6,3 1,3 0,2 1,1 12 2,2 0,5 1,5 2,3 1,3 3,6 3,7 1,2 2,2 1,4 0,1 2,6 2,2 2,4 12 9,6 1,7 0,2 3,7 5,5 1,8 4,7 2,7

13 In line with Article 39(3) of Regulation (EU) No 165/2014.  

8 

 
 
 
 
 
8. Offences detected at the roadside 

On average, 50% of all detected offences were found during roadside controls in the EU, which 
is a decrease compared to 60% in the last report. The offence rates found at the roadside across 
the EU were very diverse. Compared to the EU average of 2.11 offences per 100 working days 
checked, offence detection rates are particularly high in Slovenia (44.67), Greece (11.51), and 
Austria (7.70), and significantly more than the EU average in Cyprus (4.23), Ireland (3.77), 
Malta (3.73) and Poland (3.71). Very low offence rates at the roadside were reported in Finland 
(0.24), Bulgaria (0.24), Belgium (0.57), Denmark (0.46), France (0.82), Hungary (0.69), Latvia 
(0.27), the Netherlands (0.64) and Romania (0.27). Except the Netherlands, these are the same 
countries  with  very  low  offence  rates  as  in  the  previous  reporting  period. A  considerable 
increase in detection rate was observed in Slovenia (from 2.69 to 44.67) and in Cyprus (from 
1.11 to 4.23), while a decrease was observed in Malta (from 12.50 to 3.73), i.e. the  country 
which reported increase in detection rate in 2019-2020.  

9. Offences detected at the premises 

On average, almost 50% of all detected offences were found during controls at the premises in 
the EU, which is an increase compared to 40% in the last report. Offence detection rates at the 
premises of undertakings in the EU are also significantly diverging14. Several Member States 
were well above the EU average of 3.81 (2.59 in 2019-2020) with the highest detection rate in 
the Netherlands (16.80), Cyprus (17.03), Poland (17.90), and Germany (7.19). This stands in 
contrast  to  countries  with  a  very  low  detection  rate  such  as Austria  (0.83),  Bulgaria  (0.07), 
Croatia (0.72), Denmark (0.46), Estonia (0.66), Greece (0.04), Portugal (0.06), Romania (0.04) 
and Slovenia (0.66).  

Compared to 2019-2020, there is a significant rise in detection rates in Cyprus (from 12.02 to 
17.03), Poland (from 9.04 to 17.9015), the Netherlands (from 12.55 to 16.8016) and Lithuania 
(from  1.11  to  4.35),  while  rates  significantly  decreased  in  Finland  (from  7.49  to  4.80)  and 
Luxembourg (from 7.61 to 3.63).  

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 2021-2022. Incorrect functioning 
of the tachograph and the manipulation and misuse of the tachograph were at the same level 
(6% of the overall offences) (9% and 4% respectively in 2019-2020) at the roadside. However, 
in Malta (39%) and the Netherlands (35%), manipulation and misuse even made up around a 
third of their offences found.   

Looking  at  national  figures  for  other  types  of  infringements,  the  detected  infringements  on 
driving  time  were  particularly  high  in  Luxembourg  (36%),  Malta  (39%)  and  Spain  (37%), 

14 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 to make the comparison. 
15  In Poland, detection offence rate was 16.68 in 2017-2018.  
16 The Netherlands presents an increasing trend of offences detecting at premises.  

9 

 
 
 
while  offences  on  breaks  were  high  in  Cyprus  (48%),  Ireland  (36%)  and  Slovakia  (34%). 
Offences on rest periods were significant in Belgium (45%) and Finland (43%). In the Czech 
Republic (48%), Latvia (65%) and Italy (36%), the share of infringements related to the lack 
of driving records is significant compared to the majority of Member States. The EU average 
for infringements of lack of records for other work is very low in the majority of Member States 
(EU average being 12%), but constitutes a greater share in the Member States such as Bulgaria 
and Slovenia (21%) and Poland (32%).   

11. Categories of infringements detected at premises  

The  main  types  of  infringements  detected  at  the  premises17  of  undertakings  remain  stable 
compared to the last report. 

The  number  of  infringements  detected  regarding  breaks  decreased  from  24%  to  20%,  rest 
periods from 17% to 15%, while infringements related to driving time (9%) remained stable. 
The number of infringements detected for lacking driving time records decreased from 40% to 
35%. This offence was significantly noticed at the premises of undertakings in Poland (74% of 
offences detected at premises), Italy (55%), and Hungary (69%).  

A high number of driving time offences was detected in Greece (45%), Lithuania (64%) and 
Romania  (45%).  Offences  on  breaks  were  frequently  detected  in  Ireland  (56%),  Denmark 
(51%),  Finland  (51%)  and  Cyprus  (60%).  Infringements  on  rest  periods  constituted  a  great 
share in Belgium (57%), Estonia (64%), Malta (57%) and Portugal (47%).   

Offences on recording equipment constituted 13% and amounted to 192,810 offenses (26,926 
in  2019-2020).  Their  national  share  was  particularly  high  in  the  Netherlands  (53%). 
Infringements on the lack and availability of records of other work were in particular high in 
Germany where they constituted 16% of the national offences detected at the premises.  

Table 4: Breakdown of offences found at the roadside and premises in 2021-2022 

Checks at  Breaks 

Rest 
periods 

Driving 
time 

Roadside 
Premises 
Total 

15% 
20% 
18% 

24% 
15% 
19% 

19% 
9% 
14% 

Driving 
time 
records 
19% 
35% 
27% 

Recording 
equipment 

11% 
13% 
12% 

Lack/availability 
of  records for 
other work 
12% 
8% 
10% 

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 the required information on concerted checks and exchange of information and data 
or informed that no concerted checks were carried out18. Out of the twenty-two Member States 
that  did  provide  information  on  checks,  ten  Member  States19  met  the  required  number  of 
concerted checks in the reporting period.   

17 Latvia did not provide categorisation of offences at the premises.  
18 Croatia, Cyprus, Greece, Finland, Malta.  
19 Austria, Belgium, Denmark, France, Germany, Italy, Lithuania, the Netherlands, Slovenia and Romania. Spain 
met the target in 2021 and in 2022.  

10 

 
 
 
 
Most  Member  States  participated  in  concerted  checks  through  the  European  Traffic  Police 
Network  (ROADPOL)20,  Euro  Control  Route  (ECR)21  and  the  European  Labour Authority 
(ELA) cooperation. The support of the 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  reconfirmed  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  2021-2022.  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 

2021 
Concerted checks:  
•  6 with ECR/Tispol Member States 

2022 
Concerted checks:  
•  7 with ECR/Tispol Member States 

Belgium 

Bulgaria 

2021-2022 
Exchange of experience and information:  
5  bilateral  (11  persons  involved)  and  4  multilateral  (9  persons  involved)  with 
ECR/Tispol  Member  States.  Subject  of  the  exchange:  Driving  time  checks, 
Manipulation of recording equipment, Technical checks, Securing cargo. 
2021-2022 
Concerted checks: 
•  8 coordinated checks per year organised with ECR and Roadpol.  
•  15 actions organised on a regular basis with the Netherlands, France, Germany 

and Luxemburg. 

Exchange of experience and information:   
Exchange of experience during the meetings with ECR about the control methods. 
2021 
Concerted checks:  
•  2  joint  inspections  with  Romanian  control  bodies  (ARR)  in  Romania  and 

Bulgaria. 

Exchange of experience and information: 

20 The statutes of the European Public Association called “ROADPOL European Roads Policing Network” were 
signed  in  Dublin  on  26  September  2019  and  replaced  TISPOL  from  the  year  2020,  maintaining  the  same 
objectives. All Member States of the European Union, except Greece and Slovakia, participate in the ROADPOL 
Network, as well as Serbia, Switzerland, Türkiye and the Dubai Emirate Police.  
21 Euro Control Route (ECR) is composed of 14 EU-Member States (Austria, Belgium, Croatia, France, Germany, 
Hungary,  Ireland,  Luxembourg,  Poland,  Romania,  The  Netherlands,  Spain)  and  the  United  Kingdom.  Czech 
Republic and Slovenia are observers.  

11 

 
 
 
 
 
 
 
Croatia 

Cyprus 
Czech 
Republic 

•  Exchange  of  information  on  established  violations  committed  by  Bulgarian 
drivers on the territory of Germany, Hungary, Austria, Spain, United Kingdom, 
Italy, Latvia, Romania, Slovenia. 

2022 
Concerted checks:  
•  2  joint  inspections  with  Romanian  control  bodies  (ARR)  in  Romania  and 

Bulgaria. 

•  1 with Dutch control authorities in the Netherlands and Bulgaria. 
•  2 with Croatian control authorities in Croatia and Bulgaria  
•  1 with Belgian control authorities in Belgium and Bulgaria.                                  

Exchange of experience and information: 
•  Exchange of information on established violations in Spain between all Europe 

countries in Madrid. 

During 2021 and 2022, joint inspections were carried out on a smaller scale in order 
to prevent the spread of the COVID infection. 
No information provided 
2021-2022 
Concerted checks: 
In 2022, the Joint Scrutiny Actions were still not fully resumed, mutual cooperation 
mostly concerned the working groups under ECR:  
•  7. 09.2022: Bilateral Joint Control Activity with BAG Germany, Saxony 
•  7.10.2022:  ADR-ADR  Cross  border  enforcement  (ACE),  Plzeň  (Czech 
Republic)  with  the  participation  of  19  foreign  inspectors,  Joint  Road 
Inspection, for all control entities involved in the enforcement of new measures 
relating to the single labour market in road transport, in particular posting of 
workers.   

•  11-12.10.2022:  Slovakia,  Bratislava  with  the  participation  of  the  Czech 

authorities.  

•  13-14.10.2022:  Belgium,  Tessenderlo  with  the  participation  of  the  Czech 

authorities.  

2021-2022 
Exchange of experience and information: 
•  3.06.2022: Conference of the Union of Transporters of Poland, Lower Silesia 
Region;  presentation  of the  CSPSD  in  the  roadside  inspection  system  in  the 
Czech Republic (7 inspection weeks of the ECR with the participation of the 
Czech Republic). 

Denmark 

2021 
Concerted checks: 
•  6 with the participation of the Danish Police. 

2022:  
Concerted checks: 
•  6 with the participation of the Danish Police. 

Estonia 

Exchange of experience and information: 
•  The Danish Police exchanged information with other EU countries concerning, 

for example, procedures, interpretation of the Regulations, data, etc. 

2021 
Concerted checks: 
•  1 common roadside check of the Estonian Police and Border Guard with the 

Latvian enforcement authorities.  

12 

 
 
 
 
 
 
 
•  4 concerted checks of the Estonian Police and Border Guard with all Roadpol 

members (Trucks and Bus checks weeks). 

2022:  
Concerted checks: 
•  4 concerted checks of the Estonian Police and Border Guard with all Roadpol 

members (Trucks and Bus checks weeks).                                                                                                                                                       

Finland 
France 

Exchange of experience and information: 
•  The  representatives  of  the  Estonian  Police  and  Border  Guard  Board,  the 
Estonian  Labour  Inspection  and  the  Ministry  of  Economic  Affairs  and 
Communications participated in the conference “Changes and challenges in the 
road transport sector of the Baltic States triggered by the Mobility Package I” 
organized by ELA in Latvia on 3 November 2022. The representatives of the 
Estonian Police and Border Guard Board and the Estonian Labour Inspection 
participated  as  observers  in  the  common  roadside  checks  in  Croatia  on  13-
15.06.2022 and in Belgium on 03-05.10.2022. 

No information provided 
2021 
Concerted checks: 
•  8 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 
securing loads 
transport of dangerous goods 
transport of passengers 

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

Exchange of experience and information: 
•  Participation in   
- 

one-day  webinair  organised  by  Germany  on  Mobility  Package  1  (four 
participants from France) 
one-week training session on frauds organised by Germany (2 particpants from 
France)  

- 

2022 
Concerted checks: 
•  7 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 
- 
securing loads 
- 
transport of dangerous goods 
- 
transport of passengers 
-  weight and dimension rules 
- 
France participated in all weeks of planned inspections. 

cabotage 

Exchange of experience and information: 
-  Masterclass (fraudes and tachographs): 2 x 1 week in Germany (2 participants 

from FR);  

-  Multilateral  echange  (exchange  of  professional  practices,  etc.):  2  days  in 

Germany (2 participants from FR);  

13 

 
 
 
 
 
 
 
-  Multilateral  exchange  (exchange  of  professional  practices,  etc.):  1  week  in 

Romania (2 participants from FR); 

-  GT  TECHCA  (technical road  inspection  and  security):  1  week  in  Poland  (2 

participants from FR); 

-  Dangerous goods control / ADR: 1 week in Germany (1 participant from FR). 

In addition, in cooperation with ELA: 
-  Exchange/concerted checks in France (port de Roscoff)- FRANCE/IRLANDE 

- 2 jours (7 participants from FR) ; 

-  Exchange/concerted checks in France and in Denmark- FRANCE/DENMARK 

- 2 x 2 days (5 participants from FR) ; 

-  Exchange/concerted  checks  in  France  -  FRANCE/SLOVENIA  -  2  days  (5 

participants from FR) ; 

-  ROADSHOW  -  Presentation  of  rules  for  posted  empoyees  in  Lithuania  and 

Q&A session - Webinaire of 0,5 day (1 participant from FR) ; 

-  Workshop  Transport  routier  et  dumping  social  -  1  day  in  Belgium  (2 

participants from FR) ; 
IMI-PROVE - Webinaire of 1,5 days (2 participants from FR). 

- 
Within the framework of the “Transport” group of the Franco-Belgian Arrangement 
(AFB):  the  transport  control  agents  of  Hauts-de-France  and  Grand  Est,  with the 
services of labour inspectorates, meet their Belgian counterparts (transport control 
bodies, federal and municipal police) once or twice a year, with the objective of 
carrying out coordinated or joint controls. 
Concerted checks in 2021-2022: 
•  79 controls with German neighbouring states, Road POL, TWG, TIPSOL.  

Exchange of experience and information: 
No information provided 
No information provided 
2021-22 
Concerted checks: 0 

2021-22 
Exchange of experience and information: 
•  The  cooperating  countries  were:  Czech  Republic,  Slovakia,  Austria  and  
Poland, on most common data exchange regarding vehicles in poor technical 
condition. 

2021-2022 
Concerted checks: 
Since Brexit, collaboration with French counterparts with the assistance of ELA. 
Concerted checks are not practical between Ireland and France, and instead joint 
inspections are preferred.  
Also  work  continued  with  colleagues  in  the  UK  via  Tripartite  Grouping  and 
typically joint activity once per quarter was organised. 

2021 
Concerted checks: 
•  14 joint operations were carried out in the context of ROADPOL at European 
level, involving the simultaneous carrying out of targeted operations, each on 
its  own  national  territory,  by  all  the  participating  States,  and  with  the 
participation of the Italian Traffic Police with its own staff and within a national 
territorial scope: 
- 

4 Truck & Bus operations, to check professional drivers of vehicles used 
for the transport of persons and goods; 
1 Seatbelt operation to check the correct use of restraint systems;  

- 

14 

Germany 

Greece 
Hungary 

Ireland 

Italy 

 
 
 
 
 
- 
- 

- 

- 

- 

- 

2 Speed operations to counteract speeding; 
1 operation Speed Marathon, a fully-fledged 24-hour marathon dedicated 
to combate speed excesses;  
2  Alcohol  &  Drugs  operations,  in  order  to  verify  the  psychological  and 
physical  conditions  relating  to  the  possible  consumption  of  alcohol  and 
drugs by drivers of motor vehicles;  
1 operation Alcohol & Drugs Marathon, a fully-fledged 24-hour marathon 
to verify the psychological and physical conditions relating to the possible 
consumption of alcohol and drugs by drivers of motor vehicles;  
2  safe  Holidays  -  Safe  travel  operations,  to  check  the  normal  safety 
conditions of vehicles which, during the summer period, travel in Italy;  
1 operation Focus on the Road, to check the correct use of mobile phones, 
smartphones  and  sound  headsets  and  the  correct  use  of  safety  belts  and 
restraint devices in general. 

2022 
Concerted checks: 
•  15 joint operations were carried out at European level within the framework of 

ROADPOL, with the Italian Traffic Police throughout Italy:   
- 

4 Truck & Bus operations to control professional drivers of vehicles used 
for the transport of persons and goods: 7-13 February, 13-19 June, 18-24 
July and 10-16 October 2022;  
1  operation  Seatbelt,  to  check  the  correct  use  of  restraint  systems:  4-10 
April 2022;  
2 Speed operations to counteract speeding: 21-27 March and 8-14 August 
2022;  
1 operation Speed Marathon, a fully-fledged 24-hour marathon dedicated 
to combat speeding excesses: 24 March 2022;  
2  Alcohol  &  Drugs  operations,  to  verify  the  psychological  and  physical 
conditions  relating  to the possible  consumption  of  alcohol  and  drugs  by 
drivers of motor vehicles: 4-10 May and 5-11 December 2022;  
1  operation  Alcohol  &  Drugs  Marathon,  namely  a  24-hour  marathon  to 
verify  the  psychological  and  physical  conditions  relating  to  the  possible 
consumption  of  alcohol  and  drugs  by  drivers  of  motor  vehicles:  7  May 
2022;  
2  safe  Holidays  -  Safe  travel  operations,  to  check  the  normal  safety 
conditions of vehicles which, during the summer period, travel throughout 
Italy: 29-31 July and 26-28 August 2022;  
1 operation Focus on the Road, to check the correct use of mobile phones, 
smartphones  and  sound  headsets  and  the  correct  use  of  safety  belts  and 
restraint devices in general: 16-22 September 2022. 

- 

- 

- 

- 

- 

- 

- 

•  During  2022,  in  the  road  transport  sector,  the  National  Labour  Inspectorate 
(INL) took part in various international inspections, joint or concerted with the 
control  authorities  of  other  EU  countries  (Romania,  Belgium,  Slovakia  and 
Slovenia).  

The  activities,  carried  out  with  the  support  of  the  European  Labour  Authority 
(ELA):  
1)  concerted investigations with the Labour Inspectorates of Romania, Belgium 
and Slovakia: the checks started in December 2021, resulted from a report from 
the  Romanian  Embassy  against  a  company  group  based  in  Italy  (Ravenna), 
regarding drivers recruited by two Romanian companies and sent to Italy to be 
posted. 

15 

 
 
 
 
2)  roadside inspection in Belgium, carried out jointly with the Italian Road Police, 
with the simultaneous involvement of transport inspectors and social security 
inspectors. 

3)  roadside  check  in  Italy  (Vicenza),  carried  out  with  the  Road  Police  and  the 
Slovenian Transport Inspectors: the inspections concerned international road 
haulage and the working conditions of posted drivers and were carried out with 
the support of a mobile audit centre provided by the Ministry of Sustainable 
Infrastructure and Mobility. 

4)  activities  in  Romania  (Timisoara),  carried  out  jointly  with  the  Italian  Road 
Police and labour and transport inspectors from Spain, Belgium and Denmark. 

2021-22 
Exchange of experience and information: 
Participation in training and information exchange initiatives aimed at providing 
support and advice to businesses and trade associations. 
2021-2022 
Concerted checks: 
•  3 common roadside checks with Lithuania  
•  1 check with Estonia 

Latvia 

Lithuania 

Exchange of experience and information: 
No information provided 
2021-2022 
Concerted checks:  
•  12 cross-border concerted checks with PL.  

2021-2022 
Exchange of experience and information: 
LT officers went to 5 exchanges to BE, DE, NL, DK, EST. LT hosted 2 exchanges 
with officers from PL, SK and BE. 

Luxembourg  2021 

Concerted checks: 
Administration des Douanes et Accises : 
•  no concerted checks due to the pandemic and the reassignment of a number of 

staff trainings and meetings via videoconferencing only.  

2022: 
Concerted checks: 
- refurbishment work on the LU/FR  
- border area used for concerted checks  
- major joint control with German police   

Grand Ducal Police: 
- Inspections with Germany on the basis of the Freisener Gmentaäche. 
- Controls carried out in other settings also included road transport elements. 
- Roadpol training courses. 

Exchange of experience and information: 
•  Exchange ECR/ACE in Pilsen (CZ) with the participation of many countries. 
•  ECR meeting/exchange in Brussels.   
•  Several ECR/ACE exchanges/trainings, including online. 
No concerted check carried out in the reporting period. 

Malta 

16 

 
 
 
 
 
 
 
 
Netherlands 

2021 
Concerted checks: 
•  8 joint inspections carried out by the ILT and/or the national police within the 

ECR/ROADPOL checks.  

2022 
Concerted checks: 
•  8 joint inspections carried out by the ILT and/or the national police within the 

ECR/ROADPOL checks.  

2021-2022: 
Exchange of experience and information: 
•  A  bilateral  exchange  in  which  Germany  was  received  (1x,  8  people 
participating in total). In addition, participation took place during multilateral 
exchanges in Germany (1x, 2 persons participation in total), in Poland (1x, 2 
persons participation in total), in Romania (1x, 2 persons participation in total) 
and  the  participation  in  the  Masterclass  Manipulation  (2x,  2  persons 
participation total). 

Poland 

2021 
Exchange of experience and information: 
The representatives of the Road Transport Inspection participated in the following 
exchanges:  
international 

international 

projects 

training 

and 

• 

• 

in 

on  PM1 

2021-05-27 

2021-02-04 

enforcement 

IRU  workshop 

TECHCA  Workshop 

International workshops (on-site and online): 
(online)  
1. 
2. 
(online)  
3.  2021-07-07  ECR  Workshop  on  Dedicated  Short  Range  Communication 
(DSRC) (online) 
4. 2021-10-16-22 ECR Master Class II Workshop (Osnabrück, Germany) 
International exchanges (on-site): 
1.  2021-09-01  International  training  AT,  BE,  DK,  LT,  DE,  PL,  SE,  UK  on 
manipulation with the SCR system in heavy duty trucks (Kolding, Denmark)  
2.  2021-12-08-10  International  training  for  Balkan  control  services  PL,  BA, 
ME, XK, 1st edition of the international exchange (Belgrade, Serbia) 

Radom 

•  Meetings of working groups: 

 1.  UE:  Participation  in  6  meetings  of  working  groups  within  the  European 
Commission  
2. ECR: Participation in 35 meetings of statutory bodies, working groups and 
subgroups 
ECR 
the  ELA  working  group. 
3.  ELA:  Participation 

in  2  meetings  of 

of 

2021 

Exchange of experience and information: 
• 

International workshops (on-site and online): 
1.2022-01-17  IRU  Workshop  on  Enforcing  Mobility  Package  1  (online)  
2. 2022-05-24 ELA Enforcement of Posting Rules in Road Transport Webinar 
(online) 
3. 2022-07-04-08 ECR Expert Class Workshop (Osnabrück, Germany)  
4. 2022-07-18-22 ECR Masterclass I Workshop (Osnabrück, Germany) 
5. 2022-10-05 ELA Workshop on Passengers Transport, ERRU I (online) 
6. 
Poland)  
TECHCA  Workshop 
7.2022-10-17-19  AdBlue  and  SCR  manipulation  workshop  (Danish  Road 
Traffic Authority),(Vejle, Denmark) 
8. 2022-10-17-21 ECR Masterclass II Workshop (Osnabrück, Germany) 

2022-10-10-12 

(Radom, 

17 

 
 
 
 
 
 
• 

9. 2022-11-14 ELA Workshop on the Passengers Transport, ERRU II (online)  
10. 2022-12-06-07 ELA IMI-PROVE Program for Road Transport Workshop 
(Bratislava, Slovakia) 
International exchanges (on-site): 
1.2022-06-15 ELA Action Week - international exchange LT, PL, SK, ES in 
Lithuania (Klaipeda, Lithuania) 
2.  2022-06-29-07-01  International  training  for  Balkan  control  services  PL, 
ALB, MK, XK, 2nd edition international exchange (Skopje, North Macedonia)  
3. 2022-09-25-30 Multilateral exchange ECR HR, FR, NL, IE, DE, PL, RO, 
SK, HU, UK (Timisoara, Romania) 
4.  2022-09-26-28  ELA  Action  Week  -  international  exchange  DE,  AT,  PL 
(Neuruppin, Germany) 
5. 2022-10-04-07 Multilateral exchange ECR ADR Cross border Enforcement 
(ACE) CZ, DE, HR, RO, AT, BE, NL, PL, LU (Pilsen, The Czech Republic) 
6. 2022-10-11-12 ELAAction Week - International exchange SK, CZ, HR, BE, 
PT and PL (Kuty, Slovakia) 
7.  2022-10-14  ELAAction  Week  -  international  exchange  BE,  CZ,  SK,  PL 
(Tessenderlo, Belgium) 
•  Meetings of working groups: 

1.  EU:  Participation  in  13  meetings  of  working  groups  within  the  European 
Commission: Road Transport Committee, EWG Enforcement Working Group, 
EC RWEG expert group, EC TDG expert group on the transport of dangerous 
goods, TachoForum; 
2. ECR: Participation in 36 meetings of statutory bodies, working groups and 
subgroups  of  ECR  (including  7  on-site):  ECR  Steering  Committee,  ECR 
Executive  Committee,  ECR  Task  Force,  ECR  WG  Training,  ECR  WG 
Harmonie,  ECR  Tacho  Web  Group  (TWG),  ECR  SWG  Data  Exchange 
Harmonie, ECR SWG DRT Harmonie, ECR SWG ADR Harmonie, ECR SWG 
TECHCA Harmonie; 
3.  ELA:  Participation  in  9  meetings  of  ELA  working  groups:  ELA  WG 
Information, ELA WG Inspection and ELA Information Campaign meeting. 

Portugal 

2021-2022: 
•  Participation  in  the  relevant  meetings  organised  by  the  competent  bodies  at 

Community level. 

•  4  concerted  monitoring  activities  to  foster  the  exchange  of  experience  and 
knowledge, organised by Portugal and Spain in both countries, on the basis of 
a bilateral cooperation agreement. 
In 2022, two IMT inspectors, I.P., participated in Poland under the ECR in a 
concerted road action involving authorities from several European countries. 

• 

Romania 

2021                 
Concerted checks  
- 

8  concerted  checks  organized  by  Euro  Controle  Route  -  ECR  with  the 
participation  of  ECR  members.  Romania  participated  in  all  coordinated 
controls.    

Exchange of experience  
- 

ISCTR  representatives  have  participated  online  at  ECR  and  Corte meetings, 
IRU workshop.        

2022: 
Concerted checks: 
- 

7 concerted roadside checks organized by Euro Controle Route - ECR with the 
participation  of  ECR  members.  Romania  participated  to  all  coordinated 
controls.        

18 

 
 
                                                                                                                                       
                                                                                                                                                                                                                                                        
Exchange of experience: 
- 

ISCTR  representatives  physically  participated 
conferences, master-classes, coordinated roadside checks such as: 

in 

the  many  meetings 

-  Romania-Bulgaria bilateral roadside checks carried out in Giurgiu-Ruse during 
20-21.06.2022  with  the theme "Manipulation  of the tachograph,  driving  and 
rest periods"; 

-  Roadside checks, actions organized by the ELA (European Labor Authority) in 

Zagreb, Croatia between June 13-15, 2022; 

-  The meeting of the CORTE Working Group on enforcement practices held in 

Brussels, Belgium on November 17-18, 2022. 

-  Romania held the ECR presidency in the period July 2022-June 2023. 
-  Also, ISCTR representatives participated in online meetings. 
2021 
Concerted checks: 
No joint control actions were carried out with partner organisations from the Czech 
Republic,  Hungary  and  Poland,  as  the  inspection  authorities  of  neighbouring 
Member  States  abolished  joint  checks  on  social  legislation  in  transport  on  their 
territory. The NIP proceeded with the same step, as the COVID-19 outbreak has 
been  demonstrated  on  the  territory  of  Slovakia  and  subsequently  preventive 
inspection. 
measures 

labour 

area 

the 

of 

in 

2022 
Concerted checks: 
•  1 coordinated technical road inspection on 5 May 2022 in the Trnava region on 

the D2 motorway at the border crossing point Brodské – Břeclav;   

•  1 coordinated roadside technical inspection on 9 June 2022 in the Nitra region 

at the intersection of roads I/63 and II/511 in the municipality of Bajč;  

•  1  coordinated  technical  roadside  inspection  on  19  July  2022  in  the  Žilina 
Region  on  the  road  I/10  before  the  border  crossing  point  Makov  at  the 
BENZINOL service station. 

Exchange of experience: 
•  Participation  in  Joint  Sweep  exchanged  experiences  and  information  in  the 

field of road transport. 

2021-2022 
Concerted checks: 
•  6 per year with Croatia and Hungary22.    
•  Several joint inspections organised by ELA in France, Italy and Croatia (2x). 
These  controls  are  usually  attended  by  two  representatives  of  IRSI  and  the 
Police, and representatives. During these inspections, representatives exchange 
work experience and establish contacts for further cooperation. 

2021  
Concerted checks: 
6 ECR coordinated controls, organized by ECR-TISPOL (passengers and goods), 
about  the  following  topics:  driving  and  rest  times  and  tachograph  manipulation, 
ADR. 
holiday 

passenger 

transport, 

buses 

and 

Slovakia 

Slovenia 

Spain 

2022 
Concerted checks: 

22 Hungary did not report any concerted checks in the reporting period.  

19 

 
 
 
 
    
 
 
Sweden 

•  3  ECR  coordinated  controls,  organized  by  ECR-TISPOL  (passengers  and 
goods), about the following topics: driving and resting times and tachograph 
manipulation, technical condition, ADR. 

2021-2022 
Concerted checks: 
•  Region South of the Swedish Police hosted in 2021 and 2022 JAD TROIKA, a 
joint  Europol  collaboration.  The  operation  included  representatives  from  all 
regions of the Swedish Police as well as the Swedish Customs. The purpose 
was, in cooperation with the Swedish Customs, to search for narcotics in traffic 
coming into Sweden and for cash in traffic leaving the country. TROIKA 2022 
included training on how to discover hidden stashes in vehicles. The Swedish 
Police  participated  with  two  representatives  in  TROIKA  events  in  Holland, 
England  and  Norway.  TROIKA  2022  included  training  on  how  to  discover 
hidden stashes in vehicles. 

•  During the fall of 2022 there was a joint week of national commercial traffic 
checks in the western region of Sweden with participants from all regions of 
the Swedish Police. Other participants included police and control officers from 
Norway,  Denmark  and  Finland,  as  well  as  the  Swedish  Coast  Guard,  the 
Swedish Work Environment Authority and the Swedish Transport Agency. 

Exchange of experience: 
• 

In October 2022, two advisors from the Swedish Transport Agency participated 
in  a  CJI  organized  by  ELA  in  Finland.  Sweden  had  three  participants  in  a 
reference  group  during  a  visit  to  the  Bayerisches  Landeskriminalamt  in 
October. The purpose was to exchange information and to spread knowledge 
of Germany’s efforts to battle environmental crimes and illegal cross-border 
waste-transports.   
a 2-day digital EU-meeting of the Swedish Police with one representative in 
November 2021; IMPEL/SWEAP on illegal cross-border waste-transports. 

• 

Some Member States reported national initiatives. For example, in France, the new measures 
stemming from Mobility Package I were the subject of 3 specific mandatory webinars for land 
transport inspectors and their superiors (in March 2022). France also informed that professional 
training was accompanied by exchanges of information and cooperation23.  

In  Belgium,  29  common  actions  were  carried  out  in  the  reporting  period  between  road 
inspectors and Customs and Police services. 

In Italy, in addition to usual checks, the Traffic Police continued to carry out checks in areas of 
particular  sensitivity,  for  instance  national  and  international  road  passenger  transport  (4 
operations).  

Lithuania informed that 4 concerted checks were carried out with national labour inspectors. 

Sweden reported that in September 2022, ELA organized a one-day meeting to discuss national 
coordination in ELA-related questions. The meeting was attended by the Swedish Transport 
Agency,  the  Swedish  Work  Environment  Authority,  the  Swedish  Police,  the  Swedish  Tax 
Agency and Försäkringskassan.                                                                                                                                     

23 According  to  France,  trainers  and  stagiaires  appreciated  training  portals  such  as  www.postingdeclaration-
training.eu/scan  and  https://webgate.training.ec.europa.eu/imi-net/imi/protected/home.imi  provided  by  the 
European Commission.  

20 

 
 
 
 
 
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. Commission 
Implementing  Regulation  (EU)  2022/694  of  2  May  2022,  amending  Regulation  (EU) 
2016/40324,  introduced  new  infringements  and  new  criteria  for  defining  their  level  of 
seriousness and frequency of occurrence. For the current report, most Member States reported 
in the area and some reported changes in 2021-202225.  

In the Czech Republic, fines are imposed following an administrative procedure in which all 
aspects  of  the  individual  case  are  taken  into  account,  considering  the  level  of  gravity  of 
infringement categories set out in Annex III to Commission Regulation (EU) 2016/403. 

Denmark has still 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  being 
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 being DKK 12,000. 
After the new rules, which introduced a fine level for illegal weekly rest taken in the vehicle26, 
entered into force on 1 March 2020, taking regular weekly rest in the vehicle is considered a 
particularly aggravating circumstance.  

In Estonia, penalties provided by the Traffic Act are built on the following principle: 1 fine 
unit = 4 euros; for example the failure to use the prescribed tachograph or damaging tachograph 
is fined up to 100 fine units.          

In the Netherlands, the amount of the fines varies from €100 to €10,375 in steps of €100 and 
is based on the degree of seriousness of infringements (most serious, very serious, serious and 
minor infringements) as established by the EU rules.  

France  informed  that  new  rules  were  introduced  or  amended,  following  the  adoption  of 
Mobility Package I, notably a decree relating to the methods of calculating working time in 
public road transport companies.   

Lithuania  reported  that  in  2022  penalties  for  infringements  of  social  rules  and  misuse  of 
tachographs  were  increased  from  2  to  5  times,  e.g.  the  use  of  another  driver's  card  is  since 
considered at the same level of gravity as manipulation of a tachograph. In Spain changes were 
adopted regarding penalties for infringements relating to the leasing of vehicles with a driver. 

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. 

As foreseen by Article 19(1) of Regulation (EC) No 561/2006, adopted under Mobility Package 
I, 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 

24 Commission Implementing Regulation (EU) 2022/694 of 2 May 2022 amending Regulation (EU) 2016/403 as 
regards  new  serious  infringements  of  the  Union  rules  which  may  lead  to  the  loss  of  good  repute  by  the  road 
transport operator (OJ L 129, 3.5.2022, p. 22).  
25 France, Lithuania, the Netherlands, Spain and Sweden. 
26 Act No 139 of 25 February 2020 amending the Road Traffic Act.  

21 

 
 
 
languages27. The  information  related  to  national  penalties  is  available  on  the  Commission’s 
website28.   

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 on its own territory, 
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 2021-2022, the Netherlands  introduced an exception specifically intended for (ZE) very-
heavy company cars (i.e. company cars that run entirely on electricity, and with the battery 
pack heavier than 3,500 kg). The drivers of ZE company cars up to a maximum of 4,250 kg are 
exempt from the C driving licence requirement and the tachograph obligation, during the period 
until the permanent exemption is adopted.  

A table illustrating the exceptions adopted under Article 13 of Regulation (EC) No 561/2006, 
is available on the Commission's website29. 

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 2021-2022 and weather conditions 
(heavy rainfalls) or intense forest fires. Furthermore, in 2022, many exceptions were adopted 
due to disturbances in freight transport caused by Russia’s invasion of Ukraine.  

15. Comments and proposals  

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

Greece observed that it had managed to  exceed  the  mandatory  minimum number of checks 
thanks to the procedures applied by the Independent Authority and by the bodies of the Ministry 
of Citizen Protection. 

One  of  the  most important  problems  highlighted  by  Italian  labour  inspectorates  is  a  certain 
fragmentation  of  European  legislation  in  the  road  transport  sector,  which  leads  to  a  risk  of 
overlapping infringements depending on whether they are covered by Directive 2002/15/EC or 
Regulation (EC) No 561/2006. This would lead to a duplication of administrative procedures, 
with different deadlines for contesting infringements and for the competent authorities. In this 
regard, some inspectorates would like the Directive to be revised in order to promote greater 
uniformity of procedures. 

27  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). 
28 https://transport.ec.europa.eu/transport-modes/road/social-provisions/enforcement_en  

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

22 

 
 
 
 
The Finnish authorities suggested removing the obligations imposed on self-employed drivers 
under  Directive  2002/15/EC,  as  these  provisions  create  unnecessary  administrative  burdens 
and Regulation 561/2006 is sufficient for self-employed drivers. 

Slovakia  pointed  out  the  lack  of  drivers’  knowledge  of  the  various  legal  provisions,  and  in 
particular the provisions of the European regulations, and even when drivers attend training 
courses,  these  training  courses  do  not  always  present  the  applicable  rules,  resulting  in  their 
incorrect application in practice, especially with regard to the posting of drivers. The Slovak 
authorities consider that roadside inspections have a positive impact on drivers’ awareness of 
their rights and obligations under road transport social rules. As part of the advisory tasks, the 
inspectors provide information to the inspected drivers about cases whether they break the rules 
and, in some cases, also show them the correct operation of the recording equipment. 

As in the previous report, 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. 
They  also  reported  that  the  Swedish  Police  still  had  some  problems  with  the  systems  and 
software used to report this information during 2021. 

In the enforcement of Regulations (EC) 561/2006 and (EU) 165/2014, the Netherlands reported 
suffering  from  the  lack  of  extraterritoriality  for  infringements  of  Regulation  (EU)  No 
165/201430.  

Regarding the activities carried out in Romania, it was highlighted that the joint checks allowed 
the  exchange  of  good  practices  between  the  control  bodies  of  the  various  participating 
countries, as well as a broad discussion with operators in the sector on the different national 
legislations. Furthermore, cooperation between the enforcement authorities continued to ensure 
a  free,  competitive  and  regulated  market,  concerted  controls  and  harmonised  enforcement 
practices and methods. 

16. Interpretation of Regulations (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 several rulings. 

The question at stake in Joined Cases C-870/19 and C-871/1931 was the failure to produce the 
record sheets of the tachograph relating to the current day and several previous 28 days. In its 
judgment of 24 March 2021, the Court of Justice ruled that should the driver of a road transport 
vehicle subject to an inspection fail to produce the record sheets of the recording equipment 
relating to several days of activity during the period covering the day of the inspection and the 

30 The revision of Regulation (EC) No 561/2006 now allows the extraterritoriality for infringements of Regulation 
(EU) No 165/2014, i.e. it enables imposing a penalty after having detected an infringement of Regulation (EU) 
165/2014 which was committed on the territory of another Member State and for which a penalty has not yet been 
imposed (Regulation (EU) 2024/1258 of the European Parliament and of the Council of 24 April 2024 amending 
Regulation (EC) No 561/2006 as regards minimum requirements on minimum breaks and daily and weekly rest 
periods in the occasional passenger transport sector and as regards Member States’ power to impose penalties for 
infringements of Regulation (EU) No 165/2014 committed in another Member State or in a third country, OJ L, 
2024/1258, 2.5.2024, p. 1).  
31 Prefettura Ufficio territoriale del governo di Firenze v. MI (C-870/19), TB (C-871/19), ECLI:EU:C:2021:233.  

23 

 
 
 
previous  28 days,  the  competent  authorities  of  the  Member  State  where  the  inspection  was 
carried out must make a finding of a single infringement by that driver and impose on him or 
her only a single penalty for that infringement, and not a number of penalties for each non-
compliance occurring within the same 28-day period.   

On 8 July 2021, the Court ruled in Case C-428/1932 that Article 10(1) of Regulation (EC) No 
561/2006 must be interpreted as not precluding, in principle, a road haulage undertaking from 
granting drivers a bonus calculated on the basis of the savings made in the form of reduced fuel 
consumption in relation to the journey made. Nevertheless, such a bonus would infringe the 
prohibition  laid  down  in  that  provision  if,  instead  of  being  linked  solely  to  saving  fuel,  it 
rewarded such saving on the basis of the distances travelled and/or the amount of goods carried, 
in  such  a  way  as  to  encourage  the  driver  to  act  in  a  manner  that  endangers  road  safety  or 
infringes Regulation No 561/2006. 

In  its  judgment  of  9  September  2021  in  case  C-906/1933,  the  Court  of  Justice  judged  that 
Article 3(a) of Regulation (EC) No 561/2006  must be interpreted as meaning that a driver who 
performs  road  transport  services  falling  within  the  scope  of  that  regulation  is  obliged  to 
produce, whenever an inspecting officer so requests, the driver card, the record sheets and any 
manual record and printout made during the period consisting of the day of the inspection and 
of the previous 28 days, even when, during that period, that driver has also undertaken, in the 
same vehicle, the carriage of passengers on regular services where the route covered by the 
service in question does not exceed 50 km. It this judgment, the Court also made clear that 
Member States are precluded from imposing a penalty after having detected an infringement 
of Regulation (EU) No 165/2014 which was committed on the territory of another Member 
State and for which a penalty has not yet been imposed. The Court recognised that in so far as 
that aspect of the Union rules in force might have adverse effects on working conditions for 
drivers and on road safety, it is for the Union legislature to decide on any possible amendments. 

In its judgment of 7 July 2022 in Case C-13/2134, the Court ruled about the notion of a ‘radius 
of  up  to 100  kilometres  from  the  base  of  the  undertaking’,  within  the  meaning  of 
Article 13(1)(b) of Regulation (EC) No 561/2006. This notion must be understood as referring 
to a straight line not exceeding 100 km, drawn on the map from that base and joining the base 
to  any  point  in  a  circular  geographical  area  surrounding  that  same  base. Article 13(1)(b)  of 
Regulation  No 561/2006  must  be  interpreted  as  meaning  that,  where  a  Member  State  has 
granted, on the basis of that provision, exceptions from Articles 5 to 9 of that regulation, which 
are applicable to the carriage of goods by vehicles covered by that provision, and where those 
vehicles  carry  those  goods  not  only  within  a  radius  of  up  to 100 km  from  the  base  of  the 
undertaking concerned, but also outside of that radius, those exceptions are applicable only to 
the carriage of goods by those vehicles which does not occur outside of that radius. 

Regarding judicial interpretation by national courts, the Member States reported few national 
Court decisions interpreting Directive 2002/15/EC during 2021-2022.  

32 OL and Others v Rapidsped Fuvarozási és Szállítmányozási Zrt, ECLI:EU:C:2021:548.  
33  Criminal proceedings against FO, ECLI:EU:C:2021:715.  
34 Pricoforest SRL v Inspectoratul de Stat pentru Controlul în Transportul Rutier (ISCTR), ECLI:EU:C:2022:531. 

24 

 
 
 
Estonia reported that legal disputes concerning the implementation of Directive 2002/15/EC 
had been settled by the courts of first instance and that 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 the reporting period.  

Federal 

German 

The 
Goods 
(BAG) rules that according to Article 10 of Directive 2002/15/EC, the limitation of working 
hours on weekdays to a maximum of ten hours, as specified in the national legislation, also 
applies to drivers. 

Transport 

Office 

the 

for 

of 

In Greece, the Supreme Court ruled that the provisions of Directive 2002/15/EC, which state 
that periods of breaks are not regarded as working time, do not preclude the adoption of national 
rules regulating such periods more favourably.  

Italy reported about two judgments of the Civil Court of Cassation issued in accordance with 
Joint Judgments of the Court of Justice of the European Union (C-870/19 and C-871/19). The 
specific question in this regard concerned a single administrative penalty to be applied in the 
event of failure to produce more than one record, extended to the failure to keep such files for 
a period of one year.  

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

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  the 
enforcement of Directive 2002/15/EC. The Bulgarian and Lithuanian authorities confirmed that 
they did not encounter problems in this regard and that the Directive appears to be effective. 
The Romanian inspectors considered that they were well trained and had sufficient equipment 
and appropriate legal powers to enable them to carry out their duties effectively and efficiently. 
From  the  Greece  perspective,  the  transposition  of  Directive  2002/15/EC  has  reinforced  the 
legal  framework  for  mobile  workers,  helping  to  deal  with  issues  such  as  the  definition  of 
working  time  and  limits  on  weekly  working  time.  According  to  the  German  Federal 
Government, Directive 2002/15/EC helps to ensure the health and safety of workers and road 
safety in general throughout the EU and to prevent distortions of competition.  

The  Swedish  authorities  emphasised  that  the  awareness  of  the  rules  increases  alongside 
inspection  activities.  The  method  used  by  the  Swedish  Transport  Agency  is  documentary 
control, during which it requests written material from employers and self-employed workers. 
The inspectors strive to have personal contact with all subjects. The objective is to promote a 
behavioral change in order to improve the social situation of drivers, road safety and to promote 
fair competition.  

However, some Member States shared specific issues they face at the national level.  

25 

 
 
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 
especially  when  a  driver  uses  different  generations  of  tachographs  in  each  of  the  driven 
vehicles, or when the driver 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 the cases of mobile workers more effectively, Cyprus suggested 
that  undertakings  should  keep  detailed  records  of  data  from  both  the  tachograph  and  other 
documents  on  the  working  time  of  these  workers  (in  line  with  Article  9  of  Directive 
2002/15/EC). 

The  Finnish  labour  inspectors  found  significant  irregularities  in  the  area  of  working  time 
records,  the  maintenance  of  working  time  schedules  and  the  monitoring  of  the  maximum 
working time limit.  

The infringements raised by Luxembourgish labour inspectors mainly concerned working time 
and missing pre-recruitment medical examinations. Working hours were checked at the same 
time as driving and rest times, but they were not statistically recorded separately. 

Slovenia reported a lack of human resources to ensure adequate enforcement of their national 
regulations under Directive 2002/15/EC. 

From the Italian perspective, the situation is quite varied at the territorial level regarding the 
implementation of the Directive. While in some regions (Trento, Treviso, Bologna, Modena, 
Ravenna, Forli and Cesena) no specific problems were found in the inspected companies, in 
most  territorial  inspectorates  detected  breaches  of  the  Directive  related  to  the  incorrect 
recording  of  working  time  performed  by  mobile  workers;  non-compliance  with  daily  and 
weekly rest periods; and the night work for more than 10 hours in any 24-hour period. These 
offences  were  often  detected  by  comparing  the  entries  in  the  work  book  established  by  the 
companies with the tachograph records installed in vehicles.  

The Italian inspectors also reported the following problems:  

-  difficulties in identifying ‘periods of availability’ in the context of the driver’s activities, 
especially when checks are carried out solely by analysing the tachograph records. In order 
to  overcome  this  difficulty,  labour  inspectors  consider  it  useful  to  obtain  information 
directly from drivers; 
the lack of adequate information and training for drivers posted from other EU countries 
on health and safety in the workplace;  
the  limitation  of  the  scope  to  mobile  workers  ‘employed  by  undertakings’  and  ‘self-
employed drivers’, thus excluding other types of drivers (e.g. partners, collaborators). 

- 

- 

The suggestions and proposals for action from the Labour Inspectorates related to:  

- 

- 

- 

the need to make the driver card data recording system ‘impermeable’ to electronic devices 
that alter the correct functioning of the tachograph and make it prone to tampering and/or 
alteration of various kinds.  
the desirability of reducing the limit on the length of night work, in view of the fact that 
consecutive driving for 4 hours at night is particularly dangerous;  
the desirability of promoting coordination systems at territorial level between the various 
constitutionally competent bodies; 

26 

 
 
- 

- 

a comprehensive revision to make the rules on working time in road more organic and less 
fragmented, including through the adoption of a single text at EU level; 
the need to strengthen controls on companies employing foreign workers. 

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

Only  11  Member  States35  clearly  indicated  that  social  partners  had  been  consulted  for  the 
purpose of this reporting exercise. This is only one number higher compared to the last report. 
Cyprus,  Germany,  Greece,  Italy  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 States.  

However,  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. 

They  also supported measures to improve the organisation of drivers' work. 

• 

In  Germany,  one  trade  union  stated  that  mobile  workers  are  always  aware  of  the  fact  that,  loading  and 

unloading  times,  waiting  times  and  changing  times  are  not  recorded  as  working  time  and  they  are  not 

remunerated. The trade unions suggested more checks carried out before the entry and exit of known large 

warehouses,  port  warehouses  and  railway  container  facilities.  It  also  recommended  better  equipment  of 

control authorities and more checks. It also believed that many of the obligations under the national rules do 

not appear to be known to the undertakings.  

• 

In Greece, one of the trade unions commented that the report on the implementation of social rules should 

refer to the main problems identified, to the actions taken and to planning how to resolve them, as well as 

regarding accidents at work in this sector.  

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

by most Italian companies with the trade unions. These agreements allowed the European rules to be adapted 

to the specific features of the Italian system, while ensuring full compliance with the general principles of 

safety and health of workers.  

35 Cyprus, Estonia, Germany, Greece, Italy, Portugal, Slovakia, Slovenia and Sweden provided information on 
which  social  partners  were  consulted  while  Finland  and  France  did  not  specify  which  social  partners  were 
consulted. Austria informed that draft report was discussed in the Parliament and was publicly available on the 
Labour Inspectorate website.   

27 

 
 
 
On the contrary, some Italian trade unions wished the agreements to be reviewed, following the important 

changes in the operating environment in the context of road transport and delivery, proposing the sectoral 

rules also at the EU level.  They also suggested, for instance, 1) mandatory information and training 

courses organised and financed by companies and dedicated to mobile workers, both in the recruitment 

phase and, subsequently, on a regular basis; 2)  stepping up the system for checking tachographs and 

providing for an adaptation of Directive 2006/22/EC, with a view to coordinating it more closely with 

Directive 2002/15/EC; 3) providing for increased sanctions against companies for failure to comply with 

the rules; 4) providing adequate overnight accommodation and to step up urban roadside checks to ensure 

adequate monitoring of compliance with working time.  

Some employers’ associations, on the other hand, pointed out the need for European legislation to pay 

greater attention to the specific organisational aspects of passenger transport, which are not adequately 

covered by Regulation (EC) No 561/2006, pointing out that a clarification of interpretation would merit, 

in particular, the concept of ‘journey length’, with regard to the cumulative nature of journeys of less 

than 50 km for the purposes of applying those rules.   

• 

In Portugal, feedback from the social partners was generally positive, however trade unions called for some 

legislative changes at EU and national level.  

• 

In  Slovenia,  employers’  associations  consider  that  'self-employed'  drivers  should  be  exempted  from 

compulsory  time-recording,  as  this  does  not  have  the  desired  effect  and  only  creates  an  additional 

administrative barrier. Conversely, they consider that all commercial passenger transport operations using 

vehicles with up to 1 + 8 passengers should be subject to compulsory time recording, as these operations 

pose a greater risk to road safety. It was also suggested that roadside checks of bus and coach drivers carrying 

out  occasional  passenger  transport  are  carried  out  when  the  vehicles  are  empty  or  waiting  in  organised 

parking areas for passengers who are on excursions or events. Mandatory recording of driver activity should 

also be prescribed for all commercial transport of passengers with vehicles up to 1 + 8 passengers.  

•  A Swedish employees association commented that it is not the implementation of the Directive itself that is 

the problem, but the compliance with current legislation. It also appreciated a tripartite dialogue organised 

by the Swedish Transport Agency, which was considered a good tool for discussing and finding solutions to 

sector specific problems and challenges.  

28 

 
 
 
20. Statistics on working days checked at the roadside and premises in 2021-2022 

MS 

Minimum 
checks 

Total 
number 
2021-2022 

At the roadside 

At the 
premises 

Min. checks 
required in 
% at 
roadside 

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 

1.409.760 
1.860.857 
1.727.791 
820.123 
140.994 
1.332.003 
660 
253.440 
1.087.535 
7.051.223 
9.465.365 
3.649.560 
3.156.609 
4.140 
8.516.226 
861.126 
924.240 
174.920 
7.115 
1.823.926 
6.552.092 
709.394 
1.760.889 
504.000 
429.149 
6.355.746 
968.220 
61.547.108 

3.619.767 
1.950.531 
4.436.931 
1.294.921 
110.736 
2.039.501 
800.611 
345.911 
2.034.246 
8.953.448 
20.417.973 
3.883.130 
1.525.858 
903.419 
9.024.037 
1.692.592 
829.453 
245.641 
1.232 
2.521.303 
8.372.594 
1.985.960 
22.265.608 
577.943 
337.851 
10.576.874 
986.225 
111.734.296 

2.860.906 
1.603.102 
2.696.606 
628.285 
40.025 
1.157.998 
470.295 
155.313 
1.178.604 
5.291.78 
16.861.158 
1.224.130 
912.047 
174.805 
7.592.753 
486.552 
520.028 
138.721 
616 
779.346 
4.911.599 
1.194.672 
13.281.063 
246.318 
36.826 
7.485.134 
466.365 
72.395.053 

758.861 
347.429 
1.740.325 
666.636 
70.711 
881.503 
330.316 
190.598 
855.642 
3.661.662 
3.556.815 
2.659.000 
613.811 
728.614 
1.431.284 
1.206.040 
309.425 
106.920 
616 
1.741.957 
3.460.995 
791.288 
8.984.545 
331.625 
301.025 
3.091.740 
519.860 
39.339.243 

79% 
82% 
61% 
49% 
36% 
57% 
59% 
45% 
58% 
59% 
83% 
32% 
60% 
19% 
84% 
29% 
63% 
56% 
50% 
31% 
59% 
60% 
60% 
43% 
11% 
71% 
47% 
53% 

Min. 
checks 
required 
in % at 
premises 
21% 
18% 
39% 
51% 
64% 
43% 
41% 
55% 
42% 
41% 
17% 
68% 
40% 
81% 
16% 
71% 
37% 
44% 
50% 
69% 
41% 
40% 
40% 
57% 
89% 
29% 
53% 
47% 

Working 
days 
checked  
in % 

7.7% 
3.1% 
7.7% 
4.7% 
2.4% 
4.6% 
3.6% 
4.1% 
5.6% 
3.8% 
6.5% 
3.2% 
1.5% 
0.7% 
3.2% 
5.9% 
2.7% 
4.2% 
0.5% 
4.1% 
3.8% 
8.4% 
21.3% 
3.4% 
2.4% 
5.0% 
3.1% 
4.7% 

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

MS 

AT 
BE 
BG 
HR 
CY 
CZ 
DK 
EE 
FI 
FR 
DE 

National 
vehicles 

837.417 
575.527 
1.533.392 
369.979 
40.025 
595.705 
314.430 
112.205 
953.982 
1.991.994 
8.144.169 

Non-
national 

1.977.082 
907.509 
337.203 
57.445 
0 
518.454 
151.995 
37.119 
124.456 
3.192.890 
7.955.138 

Third 
countries 

Total 

2.860.906 
1.603.102 
2.696.606 
628.285 
40.025 
1.157.998 
470.295 
155.313 
1.178.604 
5.291.786 
16.861.158 

46.407 
120.066 
826.011 
200.861 
0 
43.839 
3.870 
5.989 
100.166 
106.902 
761.851 

29 

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

909.551 
553.439 
156.111 
5.820.391 
212.092 
375.927 
21.066 
140 
307.255 
2.310.392 
1.143.903 
7.254.532 
99.046 
36.826 
6.736.821 
460.591 
41.866.908 

142.768 
254.767 
18.607 
1.600.892 
196.354 
61.857 
103.991 
476 
435.145 
1.458.597 
50.678 
5.425.732 
128.619 
0 
711.575 
4.842 
25.854.191 

171.811 
103.841 
87 
171.470 
78.106 
82.244 
13.664 
0 
36.946 
1.142.610 
91 
600.799 
18.653 
0 
36.738 
932 
4.673.954 

1.224.130 
912.047 
174.805 
7.592.753 
486.552 
520.028 
138.721 
616 
779.346 
4.911.599 
1.194.672 
13.281.063 
246.318 
36.826 
7.485.134 
466.365 
72.395.053 

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 

MT 

NL 

PL 

PT 

RO 

SK 

SI 

Total 
drivers 

166.302 

148.684 

91.976 

25.069 

3.267 

61.404 

31.353 

10.779 

40.963 

199.657 

806.467 

104.081 

58.309 

6.872 

525.500 

19.335 

17.932 

9.591 

22 

26.874 

329.421 

45.106 

476.129 

12.781 

21.367 

Nationals 

Non-
nationals 

3rd 
countries 

Carriage of 
passengers 

Carriage of 
goods 

49.797 

55.876 

47.333 

14.882 

3.226 

32.485 

20.962 

8.181 

32.530 

80.696 

360.378 

80.334 

30.511 

6.156 

425.704 

9.518 

12.963 

3.066 

5 

10.595 

176.678 

43.044 

393.715 

5.270 

7.228 

110.150 

82.121 

25.393 

2.357 

41 

25.545 

10.133 

2.151 

4.493 

115.040 

402.885 

13.473 

21.315 

713 

90.542 

7.126 

2.133 

6.321 

17 

15.005 

81.620 

2.054 

50.932 

6.431 

8.126 

30 

6.355 

10.687 

19.250 

7.830 

0 

3.374 

258 

447 

3.940 

3.921 

43.204 

10.274 

6.483 

3 

9.254 

2.691 

2.836 

204 

0 

1.274 

71.123 

8 

31.482 

1.080 

6.013 

818 

5.519 

6.731 

3.564 

519 

2.205 

366 

344 

1.537 

11.670 

11.346 

85.354 

241 

296 

165.484 

143.165 

85.245 

21.505 

2.748 

59.199 

30.987 

10.435 

39.426 

187.987 

795.121 

18.727 

58.068 

6.576 

12.030 

513.470 

318 

274 

340 

- 

478 

42.803 

2.401 

76.247 

1.056 

2.177 

19.017 

17.658 

9.251 

22 

26.396 

286.618 

42.705 

399.882 

11.725 

19.190 

 
 
 
ES 

SE 

467.199 

39.018 

431.199 

17.651 

33.078 

18.047 

2.922 

3.320 

2.177 

410 

435.787 

38.608 

TOTAL 

3.745.458 

2.359.983 

1.137.242 

248.233 

 271.221  

 3.445.002  

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

MS 

Total 

National 

Non-
national 

3rd 
country 

Analog. 
tachogr. 

% 
analog. 

Digital 
tachogr. 

% digital 

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 

166.302 

115.410 

91.976 

24.160 

3.267 

62.456 

31.316 

10.779 

40.963 

194.772 

49.797 

46.472 

47.196 

14.782 

3.226 

31.854 

20.961 

8.181 

32.519 

80.623 

110.150 

60.815 

11.661 

2.164 

41 

27.402 

10.097 

2.150 

4.690 

110.265 

713.119 

323.668 

348.873 

104.081 

55.082 

6.872 

80.334 

31.529 

6.156 

13.473 

18.472 

713 

525.438 

425.673 

90.512 

19.335 

13.393 

9.515 

22 

9.518 

9.548 

3.051 

5 

26.874 

10.595 

317.251 

172.369 

45.106 

43.046 

446.366 

357.392 

12.729 

21.110 

5.261 

7.333 

467.199 

428.797 

39.245 

20.172 

7.126 

1.639 

6.262 

17 

15.005 

76.788 

2.052 

55.938 

6.389 

7.855 

35.158 

17.570 

6.355 

8.123 

33.119 

7.214 

0 

3.200 

258 

448 

3.754 

3.884 

40.578 

10.274 

5.081 

3 

9.253 

2.691 

2.206 

202 

0 

1.274 

68.094 

8 

33.036 

1.079 

5.922 

3.244 

1.503 

4926 

4113 

17258 

6435 

661 

6357 

431 

2056 

6059 

25739 

46297 

48888 

3916 

656 

87178 

2848 

0 

802 

3 

2381 

40811 

10872 

78728 

428 

2537 

30942 

1006 

3% 

4% 

19% 

27% 

20% 

10% 

1% 

19% 

15% 

13% 

6% 

47% 

7% 

10% 

17% 

15% 

0% 

8% 

14% 

9% 

13% 

24% 

18% 

3% 

12% 

7% 

3% 

156637 

88251 

73428 

16420 

2588 

52851 

30885 

8494 

29454 

168997 

656542 

55193 

51092 

6216 

435248 

16487 

13393 

8713 

19 

22056 

260546 

34234 

359379 

12301 

18178 

343299 

38236 

TOTAL  3.564.138 

2.270.058 

1.043.277 

250.803 

432.328 

12% 

2.959.137 

94% 

76% 

80% 

68% 

79% 

85% 

99% 

79% 

72% 

87% 

92% 

53% 

93% 

90% 

83% 

85% 

100% 

92% 

86% 

82% 

82% 

76% 

81% 

97% 

86% 

73% 

97% 

83% 

Smart 
tacho 

4739 

23046 

1290 

1305 

18 

3428 

0 

229 

5450 

36 

10280 

0 

74 

0 

3012 

0 

0 

0 

0 

2437 

13.305 

0 

8259 

0 

395 

0 

3 

77126 

% smart 

3% 

20% 

1% 

5% 

1% 

5% 

0% 

2% 

13% 

0% 

1% 

0% 

0% 

0% 

1% 

0% 

% 

0% 

0% 

9% 

4% 

0% 

2% 

0% 

2% 

0% 

0% 

2% 

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

31 

 
 
 
 
 
 
 
 
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 

Number of 
drivers  
2021-2022 
           13,229  

Number of 
undertakings 
2021-2022 
              1,160  

Number of 
working days 
2021-2022 
758.861 

           16,765  

              3,529  

           28,004  

              5,319  

              2,332  

                 370  

                 860  

                 322  

              6,402  

                 787  

           25,200  

              2,542  

              3,644  

                 311  

           11,235  

              1,763  

           81,637  

              5,455  

           51,658  

              4,255  

           10,636  

              1,946  

              4,032  

                 754  

              4,749  

                 383  

           15,400  

              3,951  

              3,694  

                 406  

           34,677  

                 805  

              1,188  

                    53  

                    42  

                    42  

           43,301  

              1,785  

           25,280  

              3,421  

              6,952  

              1,648  

           68,196  

           24,223  

              4,573  

                 601  

              1,674  

                 335  

         107,373  

           17,525  

              9,485  

                 437  

347.429 

1.740.325 

666.636 

70.711 

881.503 

330.316 

190.598 

855.642 

3.661.662 

3.556.815 

2.659.000 

613.811 

728.614 

1.431.284 

1.206.040 

309.425 

106.920 

616 

1.741.957 

3.460.995 

791.288 

8.984.545 

331.625 

301.025 

3.091.740 

519.860 

TOTAL 

         582,218  

           84,128  

39.339.243 

32 

 
 
 
 
 
25. Statistic on types of offences at roadside 

Driving 
time 

Breaks 

Rest 
periods 

28 days 
record 
sheets 

63.547 

60.227 

30.232 

Record. 
equipm. 
incorrect 
function. 
464 

Record. 
equipm. 
misuse/ 
manipul. 
3194 

Lack/avail. 
of records 
for other 
work 
16.040 

Total 
number of 
offenses 
2021-2022 
220.390 

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 

46.686 

1.701 

529 

831 

281 

3.340 
296 

358 

600 

8.405 

66.397 

26.261 

471 

150 

16.188 

71 

2.283 

571 

9 

747 

1.613 

541 

1.437 

806 

6.054 
231 

757 

237 

2.427 

42.646 

19.807 

1.519 

2.350 

11.089 

97 

417 

388 

- 

799 

23.102 

25.709 

7.618 

9.204 

1.591 

1.859 

58.166 

7.194 

3.516 

2.803 

3.108 

2.912 

21.606 

12.506 

4.075 

2.402 

3.596 

109 

6.107 
827 

894 

1.254 

9.407 

63.875 

40.933 

1.522 

1.219 

17.844 

137 

1.942 

482 

1 

1.166 

53.097 

6.663 

10.371 

2.835 

3.990 

62.979 

13.258 

137 

857 

1.601 

140 

15.604 
32 

637 

- 

9.561 

155.285 

25.847 

266 

1.558 

27.758 

873 

1.002 

1 

- 

81 

1.522 

3.110 

2.664 

1.086 

2.565 

10.336 

43 

538 

708 

43 

67 

418 
599 

254 

49 

4.010 

54505 

3363 

999 

1307 

2715 

1 

729 

1 

0 

442 

2907 

3144 

2978 

322 

924 

5477 

98 

989 

112 

1601 

0 

329 
95 

919 

747 

8.414 

19610 

14156 

950 

6 

919 

67 

1109 

34 

9 

1740 

18191 

5981 

6825 

67 

714 

408 

47 

75 

1.389 

49 

291 

962 
95 

46 

- 

1.269 

79.465 

10.503 

599 

- 

250 

91 

499 

106 

4 

- 

9.128 

6.538 

9.158 

1.694 

32.814 
2.175 

3.865 

2.887 

43.493 

481.783 

140.870 

6.326 

6.590 

76.763 

1.337 

7.981 

1.583 

23 

4.975 

57.651 

182.179 

2.539 

1.474 

202 

3.488 

13 

239 

32.571 

36.319 

9.211 

16.452 

158.985 

33.385 

TOTAL 

284.909 

228.922 

371.212 

292.798 

87062 

87233 

177.339 

1.529.475 

33 

 
 
 
 
 
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 

PL 

PT 

RO 

SK 

SI 

ES 

SE 

Driving 
time 

Breaks 

Rest 
periods 

938 

2.727 

227 

464 

822 

1.438 

99 

188 

5.330 

6.447 

41.659 

442 

460 

403 

3.605 

- 

8.666 

594 

1 

26.212 

14.203 

201 

1.432 

2.328 

412 

9.097 

1.614 

2.044 

3.356 

37 

1.226 

7.267 

2.324 

785 

248 

20.775 

38.528 

109.247 

137 

1.012 

7.650 

6.015 

- 

1.313 

1.861 

2 

57.181 

30.939 

55 

90 

4.295 

515 

4.371 

3.293 

1.925 

8.768 

245 

2.051 

3.398 

2.643 

484 

810 

13.673 

25.373 

47.896 

383 

1.291 

4.320 

6.058 

- 

1.537 

1.421 

4 

47.153 

31.105 

241 

1.043 

4.824 

750 

11.009 

3.728 

Offenses 
for driving 
time 
records 
8 

Recording 
equipment 
incorrect 
function. 
1.365 

380 

596 

22 

31 

4.947 

163 

16 

331 

2.016 

6.083 

2 

8.694 

432 

29.328 

- 

548 

3 

- 

5.916 

459.633 

3 

9 

353 

205 

5.458 

1.909 

- 

2 

- 

524 

99 

- 

- 

58 

17 

10.598 

- 

6 

861 

1.889 

- 

261 

- 

- 

- 

392 

- 

85 

535 

17 

491 

116 

Recording 
equipment 
manipul. 

17 

79 

- 

1.002 

- 

3 

- 

2 

780 

1.877 

466 

- 

173 

- 

5.332 

- 

106 

- 

- 

156.173 

9.075 

9 

23 

54 

74 

249 

- 

Lack/avail. 
of records 
for other 
work 
- 

Total 
number of 
offenses 
2021-2022 
6.297 

- 

51 

66 

- 

241 

- 

- 

136 

- 

39.913 

13 

1.025 

- 

1.382 

- 

1.036 

- 

- 

- 

74.081 

- 

65 

60 

26 

118 

2.104 

15.310 

1.158 

4.831 

12.042 

11.695 

1.531 

1.264 

41.083 

74.258 

255.862 

977 

12.661 

13.666 

53.609 

- 

13.467 

3.879 

7 

292.635 

619.428 

509 

3.206 

12.449 

1.999 

30.793 

12.764 

TOTAL 

130.009 

304.566 

222.133 

527.086 

17.316 

175.494 

120.317 

1.497.380 

34