Vans under 3.5 tonnes: the compliance most fleets skip

A fleet of vans under 3.5 tonnes sits outside the O-licensing regime that governs heavier vehicles, and operators frequently read that as sitting outside compliance altogether. Health and safety duties, roadworthiness, driver licensing and working time obligations do not disappear with the weight.

The regime that is absent is also the one that imposed discipline

The practical effect of O-licensing is that it forces a maintenance schedule, a defect system, driver checks and a named responsible person. Remove it and none of those are mandated in the same way — so van fleets often have no inspection interval, no walkaround regime, no defect reporting route and nobody who owns it.

That is a duty-of-care exposure rather than a licensing one, and it tends to be discovered after an incident rather than before, because nothing routinely inspects it.

Grey fleet is the sharper version

Where employees use their own vehicles for work, the operator's visibility drops to near zero: condition unknown, insurance cover for business use frequently absent, licence status unchecked. The duty does not scale down with ownership, and this is the area where most organisations have the least in place.

In practice: the van fleet nobody owned

An operator with an HGV fleet and a well-run transport office also runs twenty-two vans out of three depots. The vans are procured by facilities, maintained by whoever the depot uses, and driven by staff whose licences were checked at recruitment.

Nobody is responsible for them in the sense the transport manager is responsible for the HGVs. It is not an oversight anybody made — the vans never entered the process because the process was built around the licence.

Common mistakes

• –Reading "outside O-licensing" as "outside compliance"
• –No maintenance interval, because none is mandated
• –No walkaround or defect reporting route for vans
• –Licences checked at recruitment and never again
• –Grey fleet with no check on condition, insurance or licence
• –No named owner, because the vans sit outside the transport function

Borrow the discipline you already have

Operators running vans alongside HGVs usually have everything they need already — an inspection regime, a defect reporting route, licence checking, a named person who owns compliance. The vans are outside all of it, not because anyone decided that, but because the processes were built around the licence and the vans never entered them.

Extending existing disciplines is almost always cheaper and more effective than designing a separate, lighter regime — and it avoids the situation where two standards exist and nobody can say why.

Getting this right

• –Give vans a named owner inside the transport function
• –Set an inspection interval even though none is mandated
• –Extend walkaround checks and defect reporting rather than building a lighter version
• –Re-check driver licences on a cycle, not only at recruitment
• –For grey fleet, verify condition, business-use insurance and licence
• –Include vans in whatever reporting the HGV fleet already produces

One practical test: ask who owns the vans

Ask who is responsible for the compliance of the van fleet in the same sense the transport manager is responsible for the HGVs. In most organisations running both, the honest answer is nobody — the vans are procured by one function, maintained by another, and driven by people whose licences were checked at recruitment.

That is not an oversight anybody made. The processes were built around the O-licence, and the vans never entered them because they did not have to. Naming an owner is the single change that brings everything else with it, and it is free.

• –Give vans a named owner inside the transport function
• –Set an inspection interval even though none is mandated
• –Extend existing walkaround and defect processes rather than building lighter ones
• –Re-check driver licences on a cycle, not only at recruitment
• –For grey fleet, verify condition, business-use insurance and licence