Consultation outcome

Changes to HGV and bus driving tests and allowing car drivers to tow a trailer without an extra test

Updated 25 April 2022

Applies to England, Scotland and Wales

This consultation ran from 11am on 10 August 2021 to 11:59pm on 7 September 2021.

Since the consultation closed, the government has announced that HGV driving tests will be overhauled and car drivers will no longer need to take another test to tow a trailer or caravan.

Find out more about the:

• changes to HGV and bus driving tests from autumn 2021
• new rules for towing a trailer or caravan with a car from autumn 2021

Foreword

Baroness Vere of Norbiton, Parliamentary Under Secretary of State for Transport

The previous months has made clear the vital support our road haulage industry provides and the impact it has on our economy to ensure that the supply chain is maintained. The industry and their drivers have risen to that challenge that the pandemic has thrown at us and we know that this has been in the context of historic driver shortages.

Driver testing restarted in mid-April with around 3,000 tests a day, significantly more than before the pandemic. the Driver and Vehicle Standards Agency (DVSA) is working hard to tackle the backlog by putting in place additional measures to increase the number of vocational tests available including prioritising training of full time DVSA examiners over delegated examiners and operational changes that will help reduce time taken to upgrade licence entitlement.

The proposals in this consultation are not only about the need to free up more examiner capacity but also how we can streamline the stages of tests needed and the content of trailer testing. This will benefit the speed at which drivers gain their licence entitlement, allow more focus on driving skills actually needed with more flexibility than at present and reduce unnecessary barriers in the progress of becoming qualified.

Those that wish to make vocational driving their career need to feel confident that the processes involved in qualifying for a licence support rather than hinder. In doing so we understand the need to maintain the professional standard of our vocational drivers ensuring the safety of all our road users and the proposals set out how we feel we can best achieve this while looking towards a more innovative way in which we can test our drivers.

Your views are very welcome on how we can do this.

Baroness Vere of Norbiton

1. Executive summary

The haulage and logistics industry has reported a shortage of heavy goods vehicle (HGV) drivers and is coming under considerable pressure to maintain current and future supply chain commitments. The shortage is reported to have increased over the last five years from 45,000 in 2016 to 76,000 today. This shortage is likely to become acute as the demand for haulage services increases with the country moving out of current COVID-19 restrictions, including the full reopening of the hospitality sector later this month and looking ahead to the seasonal increase in demand towards Christmas.

We recognise the haulage industry is vital to the UK’s economy. It is an integral part of domestic supply chains with links to and across many sectors – food supplies, medical products, manufacturing and construction sectors, as well as supplying hospitality providers to support the tourism industry.

During the pandemic, DVSA paused theoretical and practical driver testing, for all but essential mobile workers. There is a backlog of driving tests, as well as the normal demand for test appointments. DVSA is working hard to recover those tests.

On 20 July 2021, the Secretary of State announced a package of support measures which are intended to help address the HGV driver shortage. Some of those would need changes to legislation. This document explores those options which are intended to support an increase in the availability of DVSA large vehicle testing capacity and help encourage new drivers into the profession. The regulatory requirements to obtain a vocational driving licence do not always facilitate a swift progress for the holder from provisional to full licence status, and we want to understand what is possible to assist drivers and operators speed up this process.

We are mindful that any changes have to be balanced with ensuring road safety is maintained, particularly for those who are more vulnerable – cyclists, pedestrians and motorcyclists - and that the standards required for passing a test continue to be upheld.

2. Current rules for getting a vocational driving licence

Conducting the manoeuvres in the driving test

The current regulations require applicants for category C and D practical tests to demonstrate they can competently reverse the vehicle in a straight line and in an S-shaped curve and turn the vehicle to face the opposite way using forward and reverse gears and park it both forwards and in reverse. If the test candidate is taking a vehicle and trailer test they must also show they can uncouple the trailer and then recouple the trailer to the tractor unit.

For road safety reasons, these manoeuvres are demonstrated on an off-road area before the test candidate commences the on-road drive.

Currently, this element of the driving test is conducted by DVSA driving examiners, but the regulations could be adjusted to enable the authorisation of others to carry out these off-road elements of the test. These off-road elements could be defined as a separate part of the practical test and others authorised to conduct them (albeit DVSA examiners authorisation to carry out these elements of the test would remain so they too could continue to carry out these tests).

Staging of driving licences and tests

The legislation currently requires a driver to obtain a full car driving licence (category B) before they can apply for a provisional lorry or bus driving licence (category C or D respectively, of which C1 and D1 are sub-categories).

Drivers who passed their driving test before 1 January 1997 were granted the additional C1 and D1 (101) (not for hire and reward) and B+E (car and trailer) categories. This is sometimes known as implied rights. After that date, drivers who want to obtain one of the additional vocational categories have to apply to the Driver and Vehicle Licensing Agency (DVLA) for the provisional entitlement to be added to their licence. They also have to satisfy DVLA that they are medically fit to hold this entitlement, by undergoing a medical (although a medical is not required for B+E).

Drivers with car entitlement can apply for either provisional category C1 entitlement or provisional C (rigid lorry) entitlement or both at the same time.

Drivers who successfully pass a category C test are automatically granted C1 entitlement. They have demonstrated competence in a higher category vehicle and are deemed competent to drive a smaller lorry. They also receive provisional C+E entitlement so they can undertake training in and apply for a C+E (articulated lorry or rigid lorry with drawbar) test.

A driver cannot be granted C+E provisional entitlement without first holding a category C driving licence. Likewise in the subcategory they must first pass C1 before being granted the provisional entitlement to drive a C1+E vehicle combination.

The same arrangements are mirrored for category D1 (minibus), D (bus) D1+E (minibus and trailer) and D+E (bus and trailer).

A driver who acquires C+E entitlement will be granted C1+E entitlement. If they also already holds a bus licence he will be granted D+E entitlement – they are deemed to have the competence to drive a bus and trailer without the need to take another test.

HGV training industry

The HGV training industry is not regulated. Trainers must meet the requirements to act as a qualified driver to supervise a provisional licence holder – that they are over 21, hold a relevant licence which entitles them to drive the vehicle which is being driven by the provisional licence holder and that they have the relevant driving experience. This normally means they have held the licence for three years.

HGV trainers are not required to have their names entered onto a register in order to give paid instruction, in the way that DVSA approved driving instructors are required to do for cars. There are no qualifying examinations or regular tests conducted by DVSA to ensure that the trainer is delivering instruction to an acceptable standard. DVSA has no powers to restrict a person offering HGV training.

There are two voluntary registers which aim to monitor and improve the standards to instructors delivering HGV training:

• the National Register of LGV Instructors (NRI) which is led by the road transport industry and endorsed by DVSA
• the National Vocational Driving Instructors Register (NVDIR) which is led by the road transport industry and recognised by DVSA

Both registers recognise the importance of new HGV drivers receiving professional training and encourage them to use an instructor on either register.

Towing a trailer

The rules for car drivers who wish to tow a trailer, caravan or horsebox are different depending on when they passed their test.

Drivers who passed their car test before 1 January 1997 can tow a car and trailer combination up to 8,250kg maximum authorised mass (MAM).

Drivers who passed their car test on or after 1 January 1997 can:

• drive a car or van up to 3,500kg MAM towing a trailer of up to 750kg MAM
• tow a trailer over 750kg MAM as long as the combined MAM of the trailer and towing vehicle is no more than 3,500kg MAM

If they want to tow anything heavier, they must pass a car and trailer test (B+E).

3. Proposed changes for getting a driving licence and HGV and bus driving tests

Change 1: removing the current staging requirements for licence acquisition

We want to explore removing the licence staging arrangements for drivers who want to drive articulated lorries or a rigid lorry with a drawbar trailer. We would need to amend the Motor Vehicles (Driving Licences) Regulations 1999 to allow a car licence holder to apply at the same time for both provisional category C and C+E entitlement. A driver can then choose which test to take first. If they decide to go straight to take a test in an articulated lorry and then pass, they would be granted the following entitlements – C+E, C, C1 and C1+E.

We propose to offer the same flexibility for drivers who wish to acquire C1+E entitlement, so they can do so without first taking a test to hold a C1 licence.

Minibus, bus, minibus and trailer, and bus and trailer

To ensure equal treatment for those in both the HGV haulage industry and bus and coach industry we propose that this should also apply to minibus, bus, minibus and trailer and bus and trailer licence acquisition.

We think this will simplify the process for drivers to obtain their licence. It should also speed up the process as a driver will not have to take an additional test before qualifying as a C+E driver. This should support those in the haulage industry who need C+E qualified drivers.

Some 14,000 drivers take C+E tests each year; by removing the requirement to first have to pass a C test this should make around 20,000 additional tests available. The volume of tests for the other +E categories is fewer, but will still contribute to DVSA examiner availability.

We want to understand whether this suggestion will be welcomed by drivers and haulage operators.

• Does passing a C test first give drivers and their employers reassurance they have some experience of driving and manoeuvring a large vehicle on a public road and in operational situations?
• Would operators have more confidence in a driver if they had qualified via the existing staging route?

The current arrangements mean that a driver who passes a C test has to wait until he has received his C licence before he is able to book a C+E test appointment. Generally speaking, if the facility to automatically issue the driving licence is used, the new licence will be issued and received in a matter of days. By granting provisional C and C+E entitlement together, a driver could choose to take the category C test first and, if they pass, would then be able immediately to book a C+E test.

How will this flexibility benefit the haulage industry and drivers?

We realise that by removing the licence staging arrangement, some people may have concerns about road safety implications. We know that some drivers decide to take their C+E test as soon as they possibly can after passing the C test. We would be interested if operators, the haulage industry and insurance providers have any evidence that suggests they are more likely to be involved in an accident than a driver who has more on-road experience driving a category C vehicle before going on to take the C+E test.

The category C entitlement will need to be given at the same time as the C+E licence. Without this, the driver will be licensed to tow the larger C+E combination but would not be able to drive the C vehicle on its own. In practice, this would mean an articulated lorry driver would not be able to drive just the tractor unit, or a wagon and drag driver would not be able to drive just the rigid lorry without the trailer. This situation is not practical and would not help the industry. Granting the C licence if a C+E test is successfully passed (and likewise for C1 category if a C1+E test is taken) would avoid this.

We also need to understand how this will affect the HGV training industry.

• Can training capacity of C+E fleet be increased to service a demand for additional C+E training?
• How might the shift from C to C+E training effect training businesses?

Supervising a provisional licence holder

We will also need to consider whether the rules for qualified drivers, who are permitted to accompany provisional licence holders, need changing. Amongst other things, the qualified driver must hold the entitlement to drive the vehicle. However, for C1, D1, C1+E and D1+E vehicles, the qualified driver must have passed a test in the vehicle or hold the entitlement by passing a test in the higher category vehicle, i.e. C or D. In effect, this means that a driver with implied rights in those categories cannot act as a qualified driver because they gained their rights automatically not by passing a test. We need to consider whether it is appropriate or proportionate for that arrangement to apply to a C+E driver (who had not first taken the C test) supervising a person in a C or C1 vehicle.

Currently, it is not possible for a driver to take a test in a category they already hold on their licence. We may need to think about ways around this if a driver who passes a C+E test decides it is necessary for them to pass a C test, or if legislation for acting as a qualified driver continues to require it.

It is possible for a category C licence to be granted to a driver who is under 21 years old. However, they cannot hold provisional C+E until they have held their C licence for 6 months. We need to consider whether this restriction continues to remain.

Divergence from the current driving licence arrangements

This proposal does mean divergence from the current driving licence arrangements which were introduced when the UK was a member of the EU and which the UK continues to be aligned to. A divergence from these arrangements does not alter the fact that drivers will be able to continue to drive abroad as visitors under the Vienna Convention on Road Traffic 1968.

However, a different way of acquiring a licence may have impact on recognition of driving licences and exchange of driving licences of UK licence holders resident in the EU, arrangements for which we are currently negotiating with individual EU member states.

This would impact most on those drivers who , in some cases continue to drive on, or would wish to exchange their licence acquired in this country for one in another country and would not wish to re-take a test in the relevant member state.

We are considering what flexibilities we could put in place to minimise divergence for example giving choice to drivers on continuing to stage their category of licence acquisition or some form of ‘topping-up’ process or training which could be certified as part of the test procedures, if this is feasible within the statutory regime. 

Change 2: considering alternative arrangements for the conduct of the reversing manoeuvres

As part of the practical test, a candidate for a category C and C+E test is required to undertake a reversing exercise that is conducted off the road, on a manoeuvring area. In addition to the reversing exercise, a candidate for a C+E test is also required to show that they can safely un-couple and re-couple the trailer to the towing vehicle, often referred to as the prime mover or tractor unit.

Testing these manoeuvres separately to the other elements of the practical on-road test will free up examiner time to enable an additional on road test to be added to the daily test schedule for full time vocational driving examiners.

The manoeuvres part of the test could be assessed by nominated authorised third parties from the driver training industry. Whilst DVSA might continue to provide this part of the test, we are keen to share the responsibility with the training industry.

How do trainers and training providers see arrangements for a scheme to achieve this?

This could provide some trainers with a business opportunity, whilst also ensuring their candidates are better prepared to undertake the other on-road elements of the driving test and, if they are better prepared, then they may be more likely to pass first time.

However, the convenience of assessing manoeuvres as part of a training programme may add to the overall training and testing time. This will also mean thinking about how and when successful completion of the manoeuvres assessment is evidenced and how results from trainers are communicated to DVSA so that the on-road part of the test can take place.

Regulation and quality assurance

We would like to understand the level of regulation and DVSA quality assurance or oversight trainers would expect and be comfortable with, if we did go ahead with this proposal.

A new authorisation process is also likely to require a fee to cover DVSA’s costs associated with administration and quality assurance, and we need to understand whether trainers are able to absorb those costs or if they out-weigh any benefits of convenience.

We also need to properly assess to what extent the training industry is capable of delivering this in terms of having sufficient suitable space at training sites across England, Scotland and Wales, in order to provide such a service.

• Do trainers prefer as light touch a scheme as possible, with minimum oversight from DVSA?
• Do trainers prefer a fully regulated scheme, with statutory mechanisms for approval, revocation and quality assurance?

Equally, DVSA, and other road users, need to have confidence that trainers are properly assessing candidates so that driving standards are maintained. Prospective employers will also need to have confidence that newly-qualified category C and C+E drivers can safely reverse into loading bays and other confined areas without damaging vehicles and other infrastructure.

This measure will help to reduce the current backlog in driving test availability and should result in an increased pass rate for the manoeuvres as candidates will be better prepared having demonstrated competence in the reversing manoeuvre first.

Can the haulage and training industries identify any other benefits or costs to businesses or society?

The commercial training industry is very much geared up to providing HGV driver training. Bus driver training is also provided in-house by the bus operators, many of whom are also authorised to appoint delegated examiners to conduct tests for their own or prospective employees. We would be interested to hear if these proposals could work well for the bus and coach industry.

If this proposal is recommended, we will need to consider a new fee for the on-road test conducted by DVSA, which will require amending legislation.

Change 3: allow car drivers to tow a trailer without the need for an additional test

Another option that would help free up DVSA examiner resource to conduct vocational tests would be to consider removing the requirement for car drivers to take a B+E test (car and trailer) if they want to tow a trailer. DVSA currently conducts 30,000 B+E (car and trailer) tests a year. We have seen a steady increase in volumes during the pandemic as the public has adopted caravanning as an alternative to holidays abroad.

However, we recognise that for some trainers, their business model relies solely or significantly on training and preparing drivers for B+E tests. This would have a significant impact on those businesses, some of whom only provide B+E training.

If the test requirement were to be removed, we would continue to encourage drivers to obtain professional training before first towing a car and trailer combination. However, we recognise we would not be able to mandate that requirement so it would not necessarily ensure road safety standards were maintained or that there would be an economically viable level of work for some trainers.

This option would offer savings for individuals who would not need to take a test. There may also be some benefits for some businesses who use a car or van and trailer combination – such as gardening services or horse transportation.

The government has recently published the trailer safety report, and together with the #towsafe4freddie campaign they both highlight the risks from improperly secured trailers. The need to ensure road safety is important to the government and we understand that the public may have road safety concerns from this proposal.

We would be interested to hear the views from the insurance industry on how this might affect their ability to offer cover and any implications for costs for policies.

Are insurers likely to refuse cover if a driver has not passed at test?

This proposal does mean divergence from the current driving licence arrangements which were introduced when the UK was a member of the EU and which the UK continues to be aligned to. Drivers will continue to be able to drive abroad under the Vienna Convention on Road Traffic 1968. However, there may be an impact on the mutual recognition and exchange of driving licences arrangements currently negotiated.

4. How to respond

The consultation period began on 10 August and will run until 11:59pm on 7 September 2021.

Fill in the online questionnaire to give your views.

When you respond, tell us whether you’re doing this for yourself or for an organisation.

If you’re responding for a larger organisation, tell us:

• who the organisation represents
• how you gathered members’ views (if you can)

5. What will happen next

A summary of responses, including the next steps, will be published within three months of the consultation closing.

Contact DVSA if you have any questions about this consultation.

DVSA Policy team
consultations@dvsa.gov.uk

6. Freedom of Information and data protection

Information provided in response to this consultation, including personal information, may be subject to publication or disclosure in accordance with the Freedom of Information Act 2000 (FOIA) or the Environmental Information Regulations 2004.

If you want information that you provide to be treated as confidential, please be aware that, under the FOIA, there is a statutory Code of Practice with which public authorities must comply and which deals, amongst other things, with obligations of confidence.

In view of this it would be helpful if you could explain to us why you regard the information you have provided as confidential. If we receive a request for disclosure of the information, we will take full account of your explanation, but we cannot give an assurance that confidentiality can be maintained in all circumstances. An automatic confidentiality disclaimer generated by your IT system will not, of itself, be regarded as binding on the Department. The Department will process your personal data in accordance with the Data Protection Act (DPA) and in the majority of circumstances this will mean that your personal data will not be disclosed to third parties.

Data protection

DVSA is responsible for this consultation. Your personal data will be handled in line with their consultations privacy notice.

You can find more about how your personal data is used along with your rights within this privacy notice.

7. Glossary - vehicle driving licence classifications

Medium-sized vehicles

Category C1

You can drive vehicles between 3,500 and 7,500kg MAM (with a trailer up to 750kg).

Category C1 + E

You can drive C1 category vehicles with a trailer over 750kg.

The combined MAM of both cannot exceed 12,000kg.

Large vehicles

Category C

You can drive vehicles over 3,500kg (with a trailer up to 750kg MAM).

Category C + E

You can drive category C vehicles with a trailer over 750kg.

Minibuses

Category D1

You can drive vehicles with:

• no more than 16 passenger seats
• a maximum length of 8 metres
• a trailer up to 750kg

Category D1 + E

You can drive D1 category vehicles with a trailer over 750kg MAM.

The combined MAM of both cannot exceed 12,000kg.

Buses

Category D

You can drive any bus with more than 8 passenger seats (with a trailer up to 750kg MAM).

Category D + E

You can drive D category vehicles with a trailer over 750kg.

Annex A: Full list of consultation questions

General questions

Question 1

Please tell us in what capacity you are responding to the consultation

• A professional driver
• A member of the public
• A training organisation or trainer – what training do you offer?
• An HGV or bus operator
• An industry representative organisation
• One of the LGV voluntary registers
• An insurance provider
• A road safety organisation
• A leisure interest organisation

Question 2

Please tell us about the size of your business

• Micro – 1-9 employees
• Small 10 – 49 employees
• Medium 50 – 249 employees
• Large – 250+ employees

Question 3

Have you encountered any problems in driver recruitment in the past 24 months?

Yes
No
Don’t know

Please tell us a bit more about your experience of driver recruitment.

Question 4

Are there any other areas related to driving test rules and licensing arrangements which may act as a barrier and discourage people from considering professional lorry driving as a career choice?

Yes
No
Don’t know

If yes, please provide details.

Questions on amendment 1 – removing the current staging requirements for licence acquisition.

Question 5

To what extent do you agree or disagree with the proposal to remove the staging requirements for vocational driving licences?

Strongly agree
Agree
Disagree
Strongly disagree
Don’t know

If disagree, please explain.

Question 6

To what extent do you agree or disagree that a driver who successfully passes a category C+E or D+E test should also be granted entitlement to drive a vehicle in categories C, C1+E and C or D1, D1+E and D respectively?

Strongly agree
Agree
Disagree
Strongly disagree
Don’t know

If disagree, please explain.

Question 7

What benefits, costs, risks or dis-benefits do you think would result from this flexibility?

Do you think any benefits would result in this flexibility?

Yes
No
Don’t know
Please explain your answer below or leave blank if don’t know

Do you think any dis-benefits would result in this flexibility?

Yes
No
Don’t know
Please explain your answer below or leave blank if don’t know

Do you think any costs would result in this flexibility?

Yes
No
Don’t know
Please explain your answer below or leave blank if don’t know

Do you think any risks would result in this flexibility?

Yes
No
Don’t know
Please explain your answer below or leave blank if don’t know

Question 8

To what extent do you agree or disagree that drivers should still be able to take a category C test even if they have been granted entitlement to drive by passing a C+E test?

Strongly agree
Agree
Disagree
Strongly disagree
Don’t know

If disagree, please explain.

Question 9

How much additional demand would you expect there to be if the staging requirement is removed?

Question 10

As a prospective employer, do you agree or disagree that drivers should continue to demonstrate competence by taking a category C or D test before a C+E or D+E tests?

Strongly agree
Agree
Disagree
Strongly disagree
Don’t know

If disagree, please explain.

Question 11

Do you consider there to be any concerns for road safety should the government implement this measure?

Yes
No
Don’t know

Please supply supporting evidence where possible.

Question 12

Do you think this would impact trainers, in terms of their existing fleet of training vehicles and costs?

Yes
No
Don’t know

Question 13

To what extent do you agree or disagree that the rules for qualified drivers accompanying provisional licence holders need to allow a C+E or D+E qualified driver to supervise a C or D provisional licence holder, without having taken a C or D test?

Strongly agree
Agree
Disagree
Strongly disagree
Don’t know

If disagree, please explain.

Question 14

To what extent do you agree or disagree that the restriction which prevents a category C licence holder who is under 21 from holding provisional C+E entitlement until they have held their C licence for 6 months should continue?

Strongly agree
Agree
Disagree
Strongly disagree
Don’t know

If disagree, please explain.

Questions on amendment 2 – considering alternative arrangements for the conduct of the reversing manoeuvres.

Question 15

To what extent do you agree or disagree with the proposal to enable the reversing manoeuvres and the coupling exercise to be conducted by an authorised third party?

Strongly agree
Agree
Disagree
Strongly disagree
Don’t know

If disagree, please explain.

Question 16

Do you consider there to be any barriers for training organisations to provide an assessment?

Yes
No
Don’t know

Please supply supporting evidence where possible.

Question 17

Who do you think is best qualified to be authorised to assess the manoeuvres?

1. Existing or new HGV trainers being authorised
2. Only those trainers who are members of either of the two voluntary HGV training registers?
3. Trainers who hold specific professional qualifications
4. Other (please specify)

Question 18

What sort of scheme do you think would best support this arrangement?

1. A scheme that is as light touch as possible for authorisation and ongoing assurance, with minimal involvement from DVSA.
2. A fully regulated scheme with provision for formal quality assurance checks, removal of authorisation and an appeal mechanism.
3. Other (please specify)

Question 19

Do you consider there to be any concerns for road safety should the government implement this measure?

Yes
No
Don’t know

Please supply supporting evidence where possible.

Questions on amendment 3 – allow car drivers to tow a trailer without the need for an additional test.

Question 20

To what extend do you agree with the proposal that car drivers should be allowed to tow a trailer without the need for passing a B+E test?

Strongly agree
Agree
Disagree
Strongly disagree
Don’t know

If disagree, please explain.

Question 21

How much, on average, does a B+E training course cost a driver?

Question 22

What benefits or dis-benefits are there for a driver if they don’t need to take a B+E test?

Question 23

Please explain how this will impact your business?

Question 24

Do you think drivers would continue to want to take some training, even if a test is not required?

Yes
No
Don’t know

Please supply supporting evidence where possible.

Question 25

Do you consider there to be any implications for the insurance industry?

Yes
No
Don’t Know

Please supply supporting evidence where possible.

Question 26

Do you consider there to be any concerns for road safety should the government implement this measure?

Yes
No
Don’t know

Please supply supporting evidence where possible.

Annex B: Consultation principles

This consultation follows the government consultation principles. These principles give clear guidance to us on running consultations.

If you have any comments about the consultation process please contact:

Consultation Co-ordinator
consultation@dft.gov.uk

Consultation Co-ordinator
Department for Transport
Zone 1/29 Great Minster House
London SW1P 4DR