Restricted licence, no transport manager: who is checking your compliance?
If you run a restricted goods vehicle operator licence, you don't need to nominate a transport manager. That is written into the guidance, and it is one of the reasons the licence suits smaller businesses moving their own goods.
It can also lead to a quiet assumption that there are fewer obligations. There aren't. The promises you made when the licence was granted are the same, and on a restricted licence there is usually nobody in a dedicated compliance role to check they are being kept.
What a restricted licence covers
A restricted licence only usually allows you to carry your own goods, in the UK and the EU. If you carry other people's goods for hire or reward, you need a standard licence instead.
There is no requirement to nominate a transport manager on a restricted licence. The holder is still expected to have the knowledge to make sure the law is followed, particularly on safe vehicle operation, and has to satisfy the Traffic Commissioner on fitness to hold a licence and on financial resources.
The promises that still apply
The guidance says you must satisfy a traffic commissioner that your vehicles will be kept in a fit and serviceable condition at all times. The standard undertakings on a goods licence include:
Keeping each vehicle taxed, insured and passing its MOT.
Checking that drivers hold the correct licence for the vehicles they drive.
Keeping vehicles and trailers roadworthy, and not overloading them.
Following the drivers' hours and tachograph rules.
Having drivers complete and record a daily walkaround check before driving.
Keeping safety inspection, maintenance and driver defect records for at least 15 months.
Not exceeding the number of vehicles on the licence.
Operating only from the operating centres on the licence.
Telling the Traffic Commissioner within 28 days of relevant changes, including convictions or accepted fixed penalties, a change of company name, directors or legal entity, insolvency, or a change of address, and updating your details if your maintenance arrangements change.
What you should be able to show
A promise is only as good as the record behind it. If someone asked tomorrow, could you put your hand on:
Driving licence checks for every driver, with the dates they were done?
Daily walkaround check records, including how defects were reported and fixed?
Maintenance and inspection records for each vehicle, going back 15 months?
Drivers' hours and tachograph records, with someone checking them regularly?
Written policies that say who does each of these things and how often?
If the answer to most of those is "it's in someone's head" or "the driver knows what to do", that is the gap. Without a transport manager, the written system is what shows that the compliance work is happening.
A question for the owner
If you run a restricted licence, ask yourself who is responsible for each of those records, and when someone last checked that they were complete. If the answer is "me, and not recently", an independent look is cheaper than finding the gaps after an incident.
If you'd like to know what an auditor would ask to see on a restricted licence, get in touch at enquiries@ukfleetaudit.co.uk.
Compliant fleets don't get lucky. They get built that way.
References
GOV.UK(2026) Goods vehicle operator licensing guide. Available at: https://www.gov.uk/guidance/goods-vehicle-operator-licensing-guide (Accessed: 3 November 2026).
Driver and Vehicle Standards Agency (2026) Guide to maintaining roadworthiness: commercial goods and passenger carrying vehicles. Available at: https://www.gov.uk/government/publications/guide-to-maintaining-roadworthiness/guide-to-maintaining-roadworthiness-commercial-goods-and-passenger-carrying-vehicles (Accessed: 3 November 2026).
Driver and Vehicle Standards Agency (2016) Keeping your operator licence promises. Moving On blog. Available at: https://movingon.blog.gov.uk/2016/04/06/keeping-your-operator-licence-promises/ (Accessed: 3 November 2026).
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