Tachograph obligation
Tachograph obligation from 1 July 2026: what will change for international transport?
From 1 July 2026, the tachograph requirement will change for a new group of vehicles. The smart tachograph type 2 will also become mandatory for light commercial vehicles with a maximum authorised mass of more than 2,500 kg, including trailer or semi-trailer, when these vehicles are used for international goods transport or cabotage.
Quick navigation
- New requirement for light commercial vehicles
- Which vehicles does the new requirement apply to?
- What is the smart tachograph type 2?
- What must you be able to demonstrate during an inspection?
- Cabotage remains an important point of attention
- What does this mean for light commercial vehicles?
- What can you do now?
- Conclusie
New requirement for light commercial vehicles
For many transport companies, tachograph registration has been part of daily operations for years. But for companies operating lighter vehicles, such as vans, light truck combinations or vehicles with a trailer, this requirement may be new. That is precisely why it is important to check in time which vehicles, trips and administrative processes fall under the new rules.
The change is not only about installing a device. The tachograph requirement also affects driver instructions, planning, trip administration, driving and rest times, cabotage and verifiable transport files. Anyone driving internationally will soon not only need to carry out the trip, but also be able to demonstrate that the trip has been registered correctly.
Why is the tachograph requirement changing?
The tachograph registers driving time, breaks, rest periods, other work and driver availability, among other things. Its purpose is to enable inspection authorities to verify whether drivers and carriers comply with European rules on driving and rest times. These rules are intended to reduce fatigue, improve working conditions, increase road safety and support fair competition in road transport.
Until now, the tachograph requirement mainly applied to heavier vehicles above 3.5 tonnes. From 1 July 2026, a new category will be added: light commercial vehicles between 2.5 and 3.5 tonnes that are used for international goods transport or cabotage. The European Labour Authority specifically refers to light commercial vehicles of more than 2.5 tonnes up to and including 3.5 tonnes in international goods transport or cabotage for hire or reward.
The reason is clear. Light vehicles are increasingly being used for cross-border transport. Without a tachograph, it is more difficult to check whether drivers comply with the same driving and rest time rules as drivers of heavier vehicles. The extension of the tachograph requirement reduces this difference.
Which vehicles does the new requirement apply to?
From 1 July 2026, the requirement applies to commercial vehicles:
- with a maximum authorised mass of more than 2,500 kg, including trailer or semi-trailer;
- that are used to transport goods abroad;
- or that are used for cabotage transport;
- unless an exemption applies.
The maximum authorised mass, often abbreviated as MAM, can be found on the vehicle registration certificate. This means it is not only about the empty weight of the vehicle, but about the vehicle’s own weight plus the maximum payload. In the case of a vehicle combination, the trailer or semi-trailer also counts.
For vehicles above 3.5 tonnes, the tachograph requirement has existed for longer. For that group, recent years have mainly been about the transition to the smart tachograph type 2. For light commercial vehicles between 2.5 and 3.5 tonnes, 1 July 2026 is the key new date.
Importantly, not every vehicle above 2,500 kg automatically falls under the requirement. It depends on the type of transport, how the vehicle is used and any applicable exemptions. The Dutch government, for example, mentions exemptions for non-commercial transport, certain vehicles used by professionals to transport equipment, and vehicles between 2,501 and 3,500 kg that are used only for the company or driver when transporting products is not the main purpose.
What is the smart tachograph type 2?
The smart tachograph type 2 is the latest generation of tachograph. It records the driver’s activities and, at certain moments, also records location data using satellite technology. Among other things, the tachograph can register when a vehicle is moving, when the driver takes a break, when there is rest time and when other work is being performed.
An important difference compared with older tachographs is that the smart tachograph type 2 is better aligned with international inspection and enforcement. For example, the system automatically records border crossings. This is relevant for international transport, because it provides clearer evidence of when a vehicle was in which country.
Dedicated Short Range Communication
In addition, the smart tachograph has DSRC, Dedicated Short Range Communication. This enables inspection authorities to read certain data remotely without the vehicle having to be stopped immediately. ILT mentions the vehicle registration number, tachograph status, driver card usage status, current driving speed, calibration data and information about card use as examples of data that can be read via DSRC.
This does not mean that inspection services automatically view the full driving file remotely. According to ILT, rest times and personal data are not read remotely due to privacy legislation. The smart tachograph therefore makes inspections more targeted, but does not replace the normal inspection procedure. However, if the data shows anomalies, this may provide grounds to inspect a vehicle in a more targeted way.
What must you be able to demonstrate during an inspection?
The tachograph requirement goes beyond simply having a device in the vehicle. As an organisation, you must also ensure that the tachograph is used correctly, that the right cards are present and that the data is available when requested during an inspection. The driver must use their driver card before starting to drive. This personal card records the driver’s activities.
According to the European Commission, the driver card must store the driver’s driving activities for at least 56 days, so that inspection authorities can retrieve the information.
In practice, this means that during an inspection, the driver must be able to show data for the current day and the previous 56 days. With modern smart tachograph type 2 cards, this can normally be done via the driver card. When older cards or situations with missing data are involved, additional evidence may be needed. Think of previously downloaded data, print-outs or additional administration.
For the company, this means that tachograph data must be downloaded, stored and retrieved regularly. It must also be clear who is responsible for checking the data and what happens when deviations are found.
What does this mean for planning and administration?
For planners, a lot will change. From 1 July 2026, a trip with a van to Germany, Belgium or France may be subject to different obligations than a national trip within the Netherlands. It is therefore not enough to know only where a vehicle is going. You also need to know whether the trip is international, whether cabotage is taking place and whether the vehicle falls under an exemption.
Planning determines which vehicle and which driver are deployed. The administration must then be able to demonstrate that the trip was carried out and registered correctly. These two worlds must be properly aligned.
This means that companies need to review their internal processes. Is it checked in advance whether a vehicle is subject to the tachograph requirement? Is it clear which documents the driver must carry? And are tachograph data, waybills and trip information stored in one logical way? A TMS or driver app can help record trip information, loading and unloading moments, documents and status updates clearly. But such a system remains supplementary. The legal basis lies with the tachograph, the correct transport documents and a complete administration.
Cabotage remains an important point of attention
What is cabotage?
Cabotage is domestic transport in another country after an international trip. A Dutch carrier that unloads goods in Germany and then carries out a domestic trip in Germany, for example, is carrying out cabotage.
Specific European rules apply to cabotage. ILT explains that a carrier may carry out a maximum of three cabotage operations in the Member State where the goods have been fully unloaded after an international trip. These trips must take place within seven days. After that, the same vehicle may not carry out cabotage operations in the country where the cabotage operations were performed for four days. This is known as the cooling-off period.
There is also a second situation. When a carrier enters a Member State empty, it may carry out one cabotage operation in that Member State. That trip must be completed within three days. After that, a cooling-off period of four days also applies in the country where the cabotage operation was performed.
For carriers within the Benelux, there is an important nuance. Under the Benelux Treaty, carriers from Belgium, the Netherlands and Luxembourg are, under certain conditions, not subject to cabotage restrictions within the Benelux. ILT states that this group is also not subject to a four-day cooling-off period within the Benelux. Please note: this does not mean that all administrative obligations disappear.
ILT points out, for example, that the Benelux Treaty does not provide an exemption from registering cabotage transport in connection with the posting of drivers directive in the IMI system.
The smart tachograph type 2 makes it easier to inspect cabotage, because border crossings and vehicle movements can be established more clearly. This makes it more important for cabotage administration, tachograph data and waybills to match.
What does this mean for light commercial vehicles?
For companies with light commercial vehicles, this is probably the biggest change. Vans and light combinations were often used more flexibly than trucks in many organisations. As a result, the administration was often less formally structured.
From 1 July 2026, this will no longer always be possible for international transport. When a vehicle falls under the tachograph requirement, the related obligations also apply. This means correct use of the tachograph, use of driver cards, data retention obligations and availability during inspections.
For smaller transport companies, this can have an additional impact. They often have less dedicated compliance capacity and depend more on the knowledge of planners and drivers. Especially for these companies, it is important to make clear agreements and document processes in time.
Consider questions such as:
- Which vehicles drive internationally?
- Which vehicles have a MAM of more than 2,500 kg?
- Which trips fall under cabotage?
- Which vehicles may be exempt?
- Have driver cards and company cards been applied for in time?
- Who downloads and checks the tachograph data?
- How are deviations recorded and followed up?
By answering these questions before 1 July 2026, you prevent the new requirement from only becoming visible during an inspection.
Common risks
A first risk is that companies determine too late which vehicles fall under the new requirement. As a result, the installation of the tachograph, the application for cards or the adjustment of processes may come under time pressure. The Dutch government advises making an appointment with a garage or workshop in good time, because it expects high demand due to the extension of the tachograph requirement.
A second risk is lack of clarity among drivers. If a driver does not know when to use their driver card or which activities to register, errors will arise in the tachograph data. Such errors can be difficult to correct later.
A third risk is fragmented administration. When trip data is spread across separate systems, paper documents, emails and messaging apps, it becomes more difficult to quickly present a complete file during an inspection.
Inconsistency is also a point of attention. If tachograph data, waybills and trip registrations contradict each other, this may lead to follow-up questions or further investigation. Especially in international transport and cabotage, it is important that the trip administration forms a logical and verifiable whole.
What can you do now?
The most important step is to take inventory. Create an overview of all vehicles with a maximum authorised mass of more than 2,500 kg that drive internationally or could be used internationally. Also look at combinations with a trailer or semi-trailer.
Then check per vehicle whether the tachograph requirement applies from 1 July 2026. Do not look only at weight, but also at the type of transport, how the vehicle is used and possible exemptions.
Next, plan the installation of the smart tachograph type 2 in time when a vehicle falls under the requirement. Take workshop availability into account and prevent vehicles from being unavailable around the effective date.
Also make sure that driver cards and company cards have been applied for in time. Check whether your organisation can download, store and retrieve tachograph data. Record who is responsible for these tasks.
Finally, update your internal instructions. Drivers and planners need to know when the tachograph requirement applies, which data is important, how the tachograph must be used correctly and what needs to happen in the event of deviations.
Conclusion: prepare in time for the tachograph requirement from 1 July 2026
The extension of the tachograph requirement from 1 July 2026 is particularly important for companies that transport goods internationally or carry out cabotage with light commercial vehicles. Vehicles with a maximum authorised mass of more than 2,500 kg may require a smart tachograph type 2 from that date.
The change is therefore not only about technology. It is about control over trip registration, driving and rest times, cabotage, driver instructions and verifiable transport files.
Companies that check their fleet now, tighten their processes and properly inform their drivers will avoid surprises during inspections. The smart tachograph type 2 will therefore become not only a legal requirement, but also a reason to put the digital foundation of your transport administration in better order.
Sources and background
- Ondernemersplein, “Slimme tachograaf type 2 verplicht voor voertuigen vanaf 2.500 kg”, about the obligation from 1 July 2026, target group, exemptions and practical actions.
https://ondernemersplein.overheid.nl/wetswijzigingen/tachograaf-smt2-verplicht-boven-2500-kg/ - Europese Commissie, “Tachograph”, about the function of the tachograph, driving and rest time registration and the expansion to light commercial vehicles between 2.5 and 3.5 tonnes.
https://transport.ec.europa.eu/transport-modes/road/tachograph_en - Inspectie Leefomgeving en Transport, “Slimme tachograaf”, about how the smart tachograph works, remote checks via DSRC and which data can and cannot be read remotely.
https://www.ilent.nl/onderwerpen/goederenvervoer-over-de-weg/digitale-tachograaf/slimme-tachograaf - Inspectie Leefomgeving en Transport, “Cabotage”, about cabotage rules, consignment notes, a maximum of three cabotage operations within seven days and the four-day cooling-off period.
https://www.ilent.nl/onderwerpen/goederenvervoer-over-de-weg/cabotage - IRU, “CMR”, about CMR, eCMR and the development of digital consignment notes in international road transport.
https://www.iru.org/what-we-do/facilitating-trade-and-transit/cmr