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.
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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
Article 36 of Regulation (EU) No 165/2014 requires the driver to be able to produce records for the current day and the preceding 56 days. How to document periods outside the regulation or other activities must be checked against current rules and the specific case.
Storage
Downloaded files must be kept. It is the least visible part and the one that, in a check, is demonstrated or not demonstrated.
What should you check if the vehicle is not yet compliant?
EU law defines the requirement; classification of an offence, amounts and ancillary measures also depend on current national enforcement rules.
Do not rely on amounts copied from a guide
- Check the national rule applicable to the specific conduct
- Check the responsibilities of the undertaking, driver and other parties
- Check amounts and ancillary measures on the date of enforcement
The operational response
If a potentially covered vehicle is not compliant, reconstruct its maximum permissible mass, type of transport, routes and any exemption before assigning it to international transport or cabotage. The decision needs current legal advice, not self-assessment based on this page.
Primary sources and limits of this guide
Last reviewed: 24 August 2026. This page uses EU and ministerial sources, but does not replace assessment of the case by a qualified adviser or competent authority.
Requirement from 1 July 2026 and exemptions
Regulation (EU) 2020/1054 amends Regulation (EC) No 561/2006 and includes, from 1 July 2026, international carriage of goods and cabotage above 2.5 tonnes, including a trailer or semi-trailer. The same text contains the specific exemption for certain own-account operations between 2.5 and 3.5 tonnes.
Italian operational guidance
Italian Ministry of Infrastructure and Transport circular No 9674 of 16 April 2026 explains the new requirement for vehicles over 2.5 tonnes used in international carriage of goods or cabotage.
Records to be produced and tachograph management
The consolidated Regulation (EU) No 165/2014 governs tachographs, undertaking responsibilities and the records a driver must be able to produce.
Frequently asked questions about the obligation for vehicles between 2.5 and 3.5 tonnes.
Is the tachograph mandatory on all vans?
No. The obligation introduced from 1 July 2026 concerns vehicles with a maximum permissible mass exceeding 2.5 and up to 3.5 tonnes - trailer or semi-trailer included in the calculation - used in the international transport of goods or in cabotage. A van that only makes national routes does not fall under the obligation for this regulatory reason.
I travel both national and international routes: do the same rules always apply?
No. According to the operational indications of the Ministry of Infrastructure and Transport, drivers of vehicles between 2.5 and 3.5 tonnes carrying out both types of transport are subject to Regulation (EC) 561/2006 only when carrying out international transport or related cabotage. On exclusively domestic routes, on behalf of third parties or on your own account, that regulation does not apply.
I transport my own materials for my work: am I covered by the obligation?
Regulation (EU) 2020/1054 provides for an exclusion for vehicles between 2.5 and 3.5 tonnes used for the transport of goods not on behalf of third parties, when driving is not the driver's main activity. This is the typical case of technicians, maintenance workers and installers. However, the exclusion depends on actual operations and must be verified on a case-by-case basis, not presumed.
Do I have to prove the previous 56 days even if I was not subject to the obligation before?
Article 36 of Regulation (EU) No 165/2014 requires the driver to be able to produce records for the current day and the preceding 56 days when requested. The correct way to document activities or periods outside the regulation depends on the case and current rules and should be checked with the competent authority or qualified legal support.
What is the risk if the vehicle circulates without the required tachograph?
Operating without a required tachograph may breach EU rules and the applicable national enforcement provisions. The offence, amount, ancillary measures and allocation of responsibility must be checked at the date of inspection; this guide does not quantify them and does not replace legal assessment of the specific case.
Once the tachograph has been installed, is the fulfillment closed?
No, installation is the first step. From that moment the company must manage driving and rest times, the driver card, the periodic download of data from the vehicle memory and from the card, and their storage. It's the part that lasts, and the only part that requires a process instead of a workshop intervention.
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.