Risk bands and ERRU return for UK hauliers Jan 2026
UK road transport is getting a sharper compliance edge from 1 January 2026. Regulations laid before Parliament on 19 November 2025 and signed on 17 November reconnect the UK to the European Registers of Road Transport Undertakings (ERRU) and put operator risk bands into the national register, according to the Department for Transport text published on legislation.gov.uk.
For goods vehicle operators, two new data points are critical. The national electronic register will record the registration numbers of vehicles at an undertaking’s disposal and a risk rating band. The bands are Grey, Green, Amber and Red. During roadside checks, competent authorities will be able to see both the vehicles linked to the operator and the current band-turning what was once back‑office intelligence into a live signal of risk.
Update speed tightens. Where certain register entries previously carried a 30‑working‑day window, the law now specifies five working days. In practice, changes to key data-such as authorisations, serious infringement outcomes or copies of licences-must reach the register within a week. That reduces the lag that has often caused headaches for audits, tenders and insurance renewals.
Access rules are clarified. The new vehicle and risk‑band fields must be available to competent authorities during roadside checks. Other sensitive fields must be either provided on request or accessible directly to competent authorities. This is not a public scoreboard; it is an enforcement and regulatory tool that will nevertheless influence how counterparties assess operators.
ERRU is back, with the plumbing updated. The UK and EU Member States are described as “participating countries”, enabling real‑time exchanges. The legacy “Check Community Licence” function is replaced by “Check Transport Undertaking Data”, and a “clean check” definition standardises the logging of inspections where no issues are found. Expect fewer gaps when work crosses borders.
The infringement framework is tightened. Tachograph manipulation is spelled out as having in the vehicle or using a fraudulent device able to modify records. Speed‑limiter offences now cover having or using tampering devices. Work‑organisation infringements capture any link between wages or payments and distance travelled, delivery speed or the amount of goods carried.
Good repute is reframed to include conduct that risks distorting competition in the road transport market. Frequency calculations in the annex move from drivers to vehicles, aligning risk with the actual fleet in use. A separate list of example infringements is dropped, pointing to a cleaner, more direct set of obligations for operators and managers.
Light goods vehicles are explicitly recognised where operating under a UK licence for the Community limited to vehicles at or below 3.5 tonnes. Small van fleets running international work will be expected to maintain the same register discipline as HGV operators: every vehicle registration number recorded accurately and updated promptly.
Procurement and insurance will feel the ripple. Although the register is for competent authorities, risk bands tend to feature in due diligence. Prime contractors are likely to ask for your current band and evidence of clean checks; insurers will look closely at tachograph and rest‑time clusters when setting terms, especially where an Amber or Red band persists.
A Midlands haulier running 40 vehicles sees intermittent rest‑time breaches push the undertaking into Amber. With the band visible at the roadside and shareable through ERRU, a continental client tightens subcontracting criteria. The operator responds by re‑rostering, improving tachograph analysis and documenting clean checks to return to Green ahead of renewal talks.
A start‑up courier with 3.5‑tonne vans appears as Grey at first, reflecting limited data. Thanks to the five‑day update rule, newly added vehicles appear quickly. The firm schedules monthly internal audits and driver briefings to build a string of clean checks, aiming to present a Green band before bidding for national frameworks.
A large parcel carrier slips into Red after a fraudulent tachograph device is discovered on one unit. Board‑level focus turns to preserving good repute: the transport manager’s status must show as valid, immediate retraining is booked, and payroll removes any incentive tied to distance or speed. The insurer demands proof of system change before agreeing terms.
The register’s data model is tidied. Transport managers will carry a simple “valid” or “invalid” certificate status. For “unfit person” cases, rehabilitation options reference appropriate training of at least three months or an exam on the Regulation 1071/2009 syllabus. Place‑of‑birth fields move to a free text alphanumeric format to cut mismatches.
Timing is tight. With commencement on 1 January 2026, operators have roughly six weeks from laying to clean vehicle lists, reconcile certified licence copies, brief drivers on tachograph risks and confirm HR policies do not link pay to distance, speed or payload. The instrument, a de minimis assessment and an explanatory memorandum are available via legislation.gov.uk.
For SMEs, the takeaway is straightforward. Keep the register accurate, eliminate tampering risk, and build a run of clean checks. Do that and the band trends Green, roadside friction eases and conversations with customers and insurers improve. Leave it late and an Amber or Red label will travel with you-now across borders via ERRU.