Tachograph Download Deadlines: Driver Cards, Vehicle Units and Missed Downloads

The legal download minima

GOV.UK’s responsibilities of vehicle operators set the ordinary legal minima for digital and smart tachographs: driver cards at least every 28 calendar days; vehicle units at least every 90 calendar days. Those are calendar days, not working days. Tachograph rules also state that operators must periodically download the data and analyse it to ensure the rules have been complied with.

When you must download earlier

The ordinary minima are not the whole duty. GOV.UK lists earlier downloads that operators must meet. Missing a trigger can lose data even when the 28- or 90-day calendar still looks “green”.

Driver cards — earlier downloads

• Immediately before the driver ceases to be employed by the undertaking (this also applies to agency drivers)
• Without delay if the card is damaged or malfunctioning, if download is still possible
• Without delay if it is reasonably foreseeable that data will be erased imminently
• Where the card can only be downloaded via a vehicle unit (for example if stuck), immediately before ceasing control of the use of the vehicle
• In any case as often as necessary to ensure that no data is lost

Vehicle units — earlier downloads

• Immediately before transferring control of the use of the vehicle to another person (sale, un-hire, and similar)
• Without delay upon permanently removing the unit from service in the vehicle
• Without delay upon becoming aware that the unit is malfunctioning, if download is still possible
• Without delay if it is reasonably foreseeable that data will be erased imminently
• In any case as often as necessary to ensure that no data is lost

Busy cards with many activity changes may hold less than 28 days of history. GOV.UK notes an average day as 93 activity changes. High-change operations should treat “as often as necessary” as a real calendar risk, not a slogan.

Who owns the download calendar

Legal requirement: the operator must obtain the downloads. Naming a person, a deputy, and a leaver process is operator procedure — but without that procedure the legal duty fails in practice.

Drivers’ hours limits themselves are in HGV drivers’ hours rules. What to do with a finding once analysis runs is in tachograph infringements explained.

What to do if a download is missed

A missed window is a compliance event. It is not automatically a drivers’ hours offence on the road, but it is a failure of the operator’s download duty and it can erase evidence you cannot recover.

• Download immediately if data may still be on the card or VU
• Record what was lost, what was recovered, and who authorised the delay
• Check whether a workshop “certificate of undownloadability” is needed after a failed VU recovery
• Open analysis on whatever was recovered; do not file the .ddd and walk away
• Fix the process that missed the trigger — leave, agency exit, hire return, or calendar ownership

How files get into your system

Manual depot download with a company card and download tool remains the common path. Remote download over compatible telematics can reduce plug-in journeys when available, but it does not change the 28- and 90-day legal floors or the early triggers.

Questions operators ask

Are 28 and 90 days working days?

Do agency drivers count for the leaver download?

Yes. GOV.UK expressly says the “ceases to be employed by the undertaking” trigger also applies to agency drivers. Download before they leave your control.

If I download on day 28, have I finished?

You have met the ordinary download minimum for that cycle if no earlier trigger applied. You still must analyse the data and keep records available as set out in the operator responsibilities guide.

Does a missed download equal an infringement letter to the driver?

Not automatically. A late download is an operator-system failure. Hours or card-use findings only appear once you analyse the recovered (or incomplete) record — see tachograph infringements explained.