Tachograph obligation 2.5–3.5 t: what to do now that it is already in force
From 1 July 2026, the second-generation smart tachograph is mandatory on commercial vehicles over 2.5 and up to 3.5 tonnes used in international freight transport or cabotage. The deadline has passed: this guide helps you understand whether the rules apply to your fleet, what is required beyond installation and what to do if it is not yet compliant.
Do the rules apply to your fleet? Use three checks, not the vehicle registration number
The obligation depends not only on the vehicle, but also on how it is used. Three conditions must apply together: if any one of them does not apply, the extension introduced on 1 July 2026 does not cover that operation.
1. What type of transport do you do
The extension concerns the international transport of goods between two countries and cabotage in another state of the Union. Also included are foreign routes carried out as part of what you would call national transport, and international transport on your own account when driving is the driver's main activity.
2. On whose behalf
The third party account - "for hire or reward" in the European text - is the case in point. The own account falls into an exclusion, but not automatically: it depends on the third condition.
3. What mass, including trailer
The threshold is the maximum permissible mass above 2.5 tonnes and up to 3.5. The point that is most often overlooked: any trailer or semi-trailer is also included in the calculation. A 2.4 tonne van towing crosses the threshold as complex, and should be assessed as such.
If the three conditions hold together
The vehicle was supposed to be equipped with a second generation smart tachograph by July 1, 2026. If it is not, it is currently driving in a condition that roadside inspection detects.
July 1, 2026 is the last step of a ladder that began in 2023
The obligation arises from Regulation (EU) 2020/1054, which amended Regulation (EC) 561/2006 on driving and rest times and the regulation of the tachograph. Seeing it in isolation makes the date seem like a sudden novelty: instead it is the last of four steps.
The complete sequence
- 21 August 2023 — second generation smart tachograph on new vehicles already subject to the obligation, mainly over 3.5 t and buses
- 31 December 2024 — retrofit to the second generation for international vehicles with non-intelligent analogue or digital tachograph
- 18 August 2025 — retrofit to the second generation for international vehicles with first generation smart tachograph
- 1 July 2026 — extension to vehicles over 2.5 and up to 3.5 tonnes in international transport or cabotage
Because this date weighs more than the previous ones
The first three concerned fleets that already knew the tachograph: the model of the device changed, not the existence of the requirement. The fourth brings thousands of vans and the companies that use them into the discipline, for which driving times, driver cards and data download are new matters. It's the difference between a technical update and a process that needs to be built from scratch.
The second generation tachograph records things that the previous one did not record
Version 2 is not the same equipment with a new label. The added functions serve to make the conditions that define the obligation verifiable on the road.
Additional recordings
- Location — taken at the start of the journey, every three hours of cumulative driving and at the end
- Border crossings — recorded in the device's memory
- Loading and unloading — time and place where operations take place
- Strengthened protections against tampering
The practical consequence
A roadside check can reconstruct whether the vehicle crossed a border and when, without depending on what the driver claims. The conditions that determine the obligation — international, cabotage — become data recorded by the device, not circumstances to be proven a posteriori.
Exclusion exists, but it is not presumed: it occurs
Regulation (EU) 2020/1054 provides for an exclusion for vehicles between 2.5 and 3.5 tonnes used for the transport of goods not for hire or reward, when driving is not the main activity of the person driving.
The typical case
Technicians, maintenance workers and installers who carry materials and equipment with them to carry out their work, and who drive incidentally to that work. Here driving is a means, not the activity.
Where exclusion breaks down
If actual operations show that driving is the main part of the business, the exclusion does not hold, regardless of how the contract or corporate purpose is written. It must be assessed on a case-by-case basis based on the actual use of the vehicle.
Domestic routes only
If the vehicle carries out exclusively domestic routes, the obligation of 1 July 2026 does not apply for this specific regulatory reason. Any other rules applicable to the vehicle or activity remain unchanged.
Installation is the first day of fulfillment, not the last
The pages explaining the obligation stop at the device. The real cost begins later, and is recurring: they are weekly and monthly processes that did not previously exist in the company.
Periodic data download
The data must be retrieved from the device memory and the driver card at regular intervals and stored. Doing it by hand means stopping the vehicle, having the company card at hand and remembering it: three conditions that are missing in a small fleet during the busiest weeks.
Driving times, breaks and rests
With the entry into Regulation (EC) 561/2006 comes limits that must be respected and demonstrated, not just known.
The 56 days
The driver must be able to show the records of the current day and the previous 56 days. It is an obligation that concerns the person and which does not lapse due to the fact that the extension is recent: for the periods not covered by registrations the sector sources indicate the certificate of absences provided for by article 9, paragraph 4, of law 144/2008.
Storage
Downloaded files must be kept. It is the least visible part and the one that, in a check, is demonstrated or not demonstrated.
How much a violation weighs, and why it doesn't end in a fine
Sector sources recall the sanction of article 179 of the Highway Code.
The sanction
- From 866 to 3,464 euros
- Suspension of driving license from fifteen days to three months
- Deduction of 10 CQC points required by law; its applicability to vehicles that can be driven with only a B license is the subject of ministerial clarification
The part that is not in the table
A license suspension stops a person, and in a small fleet a stopped person is a stopped vehicle. This is why real exposure is not measured by the amount of the fine but by the days of service missed.
Sources and limits of this guide
This page describes a compliance and its operational consequences. It is not legal advice and does not replace checking your case with a consultant or the competent authority.
Sources consulted
- Regulation (EU) 2020/1054, amending Regulation (EC) 561/2006 and Regulation (EU) 165/2014
- Ministry of Infrastructure and Transport, circular no. 0009674 of 16 April 2026 — first operational indications
- Confartigianato Brescia, note dated 30 April 2026 on the new obligations from 1 July 2026
- TOPFLY, regulatory sheet updated to 21 May 2026
Last content check
18 August 2026. The matter is evolving and some application aspects - among these the reduction of CQC points for drivers with only a B license - await clarification. If you read this page long after that date, check that no changes have occurred.
Frequently asked questions about the obligation for vehicles between 2.5 and 3.5 tonnes.
The tachograph is installed. Who will hold the trial afterwards?
If the obligation concerns you, the part that lasts is the data download and its conservation. Let's see together how it is organised on your fleet.