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Compliance advice summary: driving licence changes – entitlements to drive

The UK government has announced a number of changes regarding testing and driving licences over the last few months to help relieve the pressures on our industry.


The foremost change that came into effect was to category B+E licences, which saw drivers no longer needing to take a second test to tow a trailer or caravan. The Driver and Vehicle Standards Agency (DVSA) currently conducts 30,000 B+E (car and trailer) tests a year, so removing the need to take a trailer test would free up examiners for vocational testing.

From 16 December 2021, a driver who passed their car driving test after 1 January 1997 is allowed to tow trailers up to 3,500kg Maximum Authorised Mass (MAM) behind a towing vehicle up to 3,500kg MAM. Before towing you will need to ensure the train weight of the combination is not exceeded. Although there is no legal requirement to ensure training is undertaken before towing, the Health and Safety at Work Act places an obligation on employers to ensure that employees are properly trained to use equipment they are expected to use in the course of their job.

It may also be the case that insurance providers expect the voluntary training to be undertaken by those who drive these combinations.

Due to the swift turnaround of this piece of legislation the checking of entitlement online includes a note regarding the changes, not a change to where the B+E sits, as this will still show within the provisional box. This will be updated by the Driver and Vehicle Licensing Agency (DVLA) in due course. So essentially just ensure a valid Category B entitlement is shown.

Following on from this change, a further two were implemented from 15 November 2021 to help reduce the demand for tests – consequently removing the pressure to undertake around 50,000 vocational tests a year. 


Since 1997, an individual wishing to take the test to acquire a Category CE driving licence to drive a heavy articulated vehicle could only do so once they had acquired the Category C licence to drive a rigid vehicle. This was described as staged testing. Prior to this, a holder of a car driving licence was able to take their ‘Class 1’ driving licence test (heavy articulated vehicle) without first taking their ‘Class 2’ (heavy rigid).

The DVLA data indicated that a significant number of drivers embarked upon the acquisition process for CE immediately after acquiring their Category C. It was hoped that by reverting to the pre-1997 process, when there was no staging process, they could potentially save around 20,000 vocational driving tests each year, which could be redeployed to get more new drivers qualified more quickly.

An individual who has taken only their CE test will automatically gain Category C entitlement and will be legal to drive rigid vehicles, as well as C1E and C1; these categories will appear on a licence at licence check.


Finally, the last changes are around the Driver CPC (Certificate of Professional Competence) element. Prior to 15 November 2021, tests under module 3 the ‘reversing element’ or for vehicle and trailers the ‘uncoupling and recoupling’ exercise, would have been passed by a DVSA examiner. This has now been revised and these tests can be carried out by an accredited individual in the training sector.

This part of the test is carried out off the road on a manoeuvring area and takes a significant amount of time. The change is hoped to free up DVSA examiners’ time for conducting on-road practical tests. It has been suggested that the current normal output of four tests per day by a DVSA examiner could be increased to five tests per day. The reversing/uncoupling element will now be referred to as ‘module 3a’ and the on-road test will be referred to as ‘module 3b’.

The reversing exercise (3a) must be passed before the on-road exercise (3b) can be sat – an examiner will ask to see evidence of the 3a test pass before the 3b test commences. A 3b test can be booked before a 3a is passed.

You would need to pass both parts of Driver CPC module 3 within two years, otherwise you’ll have to pass the part 1 theory test again. This is the same for passing part 2 before moving onto part 4.

Currently DVSA is referring to all four tests as Driver CPC, which you need to pass to qualify. However, we believe this could be misinterpreted. If you fall within any exemptions of the requirement from CPC, for example a mechanic, then you will only need to gain parts 1 and 3 of the DVSA’s Driver CPC which was previously referred to as licence acquisition.

Logistics UK is currently publishing regular updates on vocational test availability for 3a and 3b through our enews. If your company or test provider are finding it hard to access a test, then DVSA has established an email address to contact and they will be in touch to help – vocational.testing@dvsa.gov.uk.


One to note, legislation has been laid down which will mean that a driver who has passed either a car or HGV test on a manual vehicle, will attain both manual and automatic entitlement even if they take a test in an automatic vehicle for vocational entitlements. It is expected to come into effect early in 2022.


In 2018, the government changed the law to allow a driver who holds a Category B driving licence to drive an alternatively fuelled vehicle up to 4.25t if they had completed five hours of classroom training from an accredited trainer.

A driver who is using this derogation is driving the vehicle on category B entitlement, meaning no Driver CPC is required. A driver who passed their car test before 1 January 1997 also has C1 entitlement so can drive the same vehicles without the derogation but will be in scope of Driver CPC. If making use of alternatively-fuelled vehicles up to 4.25t in a fleet, it is important to be clear on which entitlement pre-’97 drivers are driving and that they hold either the derogation training certificate or a valid Driver CPC.

In its 2021 Transport Decarbonisation Plan, the government committed to review the derogation. Logistics UK has pressed the Office for Zero Emission Vehicles to review the process in the short and medium term, to recognise that alternatively fuelled vehicles will be the only vehicles available for sale in the UK from 2030, and to write regulation which recognises that these vehicles will be heavier (and therefore carry less payload) than their petrol/diesel counterparts.


Published On: 17/02/2022 16:00:33


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