Missing Tachograph Data and Driving Without a Card: What Should Operators Investigate?

What “missing data” usually means

In operator language, missing data covers several different gaps. Mixing them invents the wrong next step.

What the card rules actually say

Under tachograph rules, it is a legal requirement for a driver to use a driver card when driving a vehicle that is in scope of assimilated or AETR rules and fitted with a digital or smart tachograph. The vehicle will still move without a card inserted — the VU records that it was used without a card.

• A driver who has not been issued a driver card must not drive such a vehicle
• A driver who is not in possession of their issued card must not drive unless the card is lost or stolen and the GOV.UK reporting / printout procedures are followed
• It is not permitted to keep manual records merely because the card was forgotten
• Drivers may hold only one driver card and must not use anyone else’s

Drivers’ hours limits for a complete day are summarised in HGV drivers’ hours rules. An uncarded movement can be a record failure even when the driving time would otherwise have been legal.

A practical investigation order

Operator procedure: use the same order every time so “unknown” does not sit open for weeks.

If the root cause is a missed download window, fix the calendar using tachograph download deadlines before you argue about the driver’s mode switches.

Explanations that are not automatically breaches

• Workshop or calibration centre movement with the correct workshop process
• Towing or recovery where the activity is explained and evidenced
• A download that arrived late but still contains the day — analyse it
• A temporary manual non-drive day waiting for the matching .ddd
• Unmatched upload that simply needs linking to the right driver or registration

None of these absolve you from investigating. They stop you treating every red flag as a driver hours offence before the facts are in.

When it likely is a card-control problem

• In-scope driving with no card and no lost/stolen procedure
• Card withdrawn while the vehicle continues to move without a lawful reason
• Someone else’s card used
• Forgotten card with “manual chart” invented as a workaround

Confirmed card-control and hours findings then follow tachograph infringements explained.

Lost, stolen or damaged cards

Official guidance: follow the GOV.UK process for reporting and temporary printouts while a replacement is obtained. Analysis should follow that paperwork. Do not assume a blank week was rest, and do not invent a complete drivers’ hours day from memory alone.

How FleetPro surfaces gaps

Questions operators ask

Is every missing-mileage line an offence?

Can the vehicle be driven without a card inserted?

Physically yes — the VU records use without a card. For in-scope digital or smart tachograph work, the driver must use their card (with the limited lost/stolen procedures). Forgotten card is not a manual-record excuse.

Should I issue an infringement letter on day one?

Not before investigation. Gather downloads, work records and the driver’s account. Use tachograph infringements explained when you have a named finding to close.

Where does analysis fit?

Download first, investigate gaps as findings, then close confirmed breaches. The monitoring loop is digital tachograph analysis.