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Agency HGV Drivers: What to Check Before Their First Shift

Published 19/10/2026 · 5 min read

Rhys HughesDirector & Transport Manager at Operator Labs Ltd

What UK operators should check before an agency HGV driver’s first shift: licence, CPC, tachograph card, hours and working time, induction, and download triggers when they leave.

This is general guidance for UK transport managers and operators. It does not replace official DVSA or Traffic Commissioner guidance, your operator licence conditions, or legal advice.

On this page
  1. Same standard as employed drivers
  2. Checks before the first shift
  3. Hours and working time across employers
  4. Tachograph use and the leaver download
  5. Induction: what must be yours
  6. In FleetPro
  7. Questions operators ask
  8. Official sources

Legal requirement means a cited GOV.UK duty. Official guidance explains how the rules work. Operator procedure is your booking and gate process. This is general guidance, not legal advice.

Same standard as employed drivers

The goods vehicle operator licensing guide expects drivers to be correctly licensed and adequately trained for the vehicles and equipment they use. It does not create a lighter standard because the driver is supplied by an agency. If they drive your vehicle, they are in your system of control for that work.

Checks before the first shift

CheckStatusWhy it matters
Vocational licence / entitlement for the vehicleLegal requirementWrong category or expired entitlement stops the job
Driver CPC where it appliesLegal requirement (where applicable)See GOV.UK become-a-driver guidance
Tachograph driver card present and usableLegal requirement for in-scope digital/smart workForgotten card is not a manual-record excuse
Hours and rest headroom for the planned shiftLegal / scheduling dutyYou must schedule work so the rules can be met
Working-time / other-employer hours (where RT WTD applies)Legal / record dutyMobile workers must disclose other employers’ hours in writing on request
Induction to your vehicles, walkaround, defects, sitesOperator procedure + training dutyFull pack: induction checklist article
Agency booking references and emergency contactsOperator procedureWho to call when the shift goes wrong

Agency first-shift gate

  • Photo or scan of licence and CPC evidence retained to your procedure
  • Tachograph card number and expiry recorded
  • Driver confirms other work / previous duty that affects today’s hours
  • Walkaround and defect process shown on the actual vehicle type
  • Site, load and keys briefing completed
  • Named depot contact for the shift

Hours and working time across employers

Operators must properly schedule work so drivers’ hours can be met, and must take all reasonable steps to prevent breaches. An agency driver who arrived mid-week may already have driven for someone else. Ask, record, and plan the remaining legal window.

Where Road Transport Working Time applies, GOV.UK working time rules require mobile workers to inform each employer in writing of hours worked for another employer when asked. Employment agencies or businesses that pay the worker may also hold working-time records. Separate the clocks as in Working Time Directive vs drivers’ hours.

  • Do not assume the agency “already checked hours” without evidence for today’s plan
  • Do not treat a 1998-style individual opt-out story as a Road Transport 48-hour waiver
  • Keep the agency shift inside both driving limits and working-time limits where they apply

Tachograph use and the leaver download

For in-scope digital or smart tachograph work, the driver must use their own driver card. Operators must download driver cards at least every 28 calendar days and immediately before the driver ceases to be employed by the undertaking — GOV.UK expressly includes agency drivers. Details and other early triggers are in tachograph download deadlines.

  • Download the agency card before they leave your control, even after a one-day booking
  • Analyse the period they drove for you — filing .ddd files is not enough
  • Investigate gaps and no-card events; do not assume every gap is an offence

Confirmed findings follow tachograph infringements explained.

Induction: what must be yours

The agency may have generic HGV training. You still need to show your walkaround method, defect reporting route, yard rules, load types, and which hours regime this operation uses. That is why the HGV driver induction checklist exists as a separate guide — this page is the agency gate, not a second copy of every induction heading.

In FleetPro

Questions operators ask

Can I skip induction for a one-day agency booking?

Who downloads the agency driver’s card?

You must obtain the download for the period they are under your undertaking, including before they cease to be employed by you. Coordinate with the agency so the file is not lost between systems.

What if they already drove for another operator today?

Treat previous duty as real. Reschedule or refuse the shift if the remaining legal window cannot take the work. Hours and working-time rules do not reset at your gate.

Is agency supply a lighter traffic-commissioner standard?

No. Competence, records and systems of control still sit with the operator for the work done on the licence.

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Official sources

  • Goods vehicle operator licensing guide (GOV.UK)
  • Responsibilities of vehicle operators (GOV.UK)
  • Tachograph rules for goods vehicles (GOV.UK)
  • Become a qualified HGV or bus driver (GOV.UK)
  • Working time rules (GOV.UK)

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