A Ticking Time Bomb for Your Operator Licence
Over the last couple of years, I’ve carried out audits and consultancy work for a range of vehicle operators across the country. What I’ve discovered is something that every operator should take seriously, and some should see as a wake-up call. There are more Transport Managers listed on operating licences ‘in name only’ than I had previously thought.
Time and time again, I’m called in to look at compliance systems, only to find out there are no systems at all. The reason? In a lot of these cases, the company had a Transport Manager listed on their licence purely in name. Someone who doesn’t show up, doesn’t inspect records, doesn’t engage with drivers or vehicle maintenance, and frankly, isn’t fulfilling the role, but is taking payment.
Here’s what really baffles me: I have no idea why operators would be comfortable paying someone for a service but allowing them not to do the work. You wouldn’t accept this in any other part of your business. You wouldn’t pay your mechanic if they didn’t service your vehicles. You wouldn’t pay a driver who didn’t turn up for their shift. So why is it acceptable to pay a Transport Manager who never sets foot on site, never checks your systems, and never supports compliance?
Let me be clear: this isn’t a matter of ‘some’ operators being slightly behind and others mostly fine. It’s not a sliding scale. In every single case I’ve seen where the TM was absent, the operator was in serious non-compliance. We're talking about no defect reporting process, no maintenance planning, no driver management, no training records, and in some cases, no idea what the undertakings on the licence even mean
This is not only dangerous from a road safety perspective, but also a massive regulatory risk. The role of a Transport Manager is not optional. They are the named individual responsible for the continuous and effective management of the transport operation. If they’re not turning up, they're not managing anything.
And here’s the brutal truth: the Traffic Commissioner won’t look at a situation like that and shrug it off. If an audit or roadside encounter reveals systemic failures, and it becomes clear that your TM is only a name on paper, you are hurtling towards a Public Inquiry, and more than likely, revocation of your licence.
It doesn’t matter how long you’ve been operating, how nice your fleet looks from the outside, or how busy your drivers are. If your compliance is in chaos, the consequences are not just reputational, they’re operational and legal.
If you haven’t seen your TM for months, or they’ve never visited your site, ask yourself: who is managing your compliance? Who’s checking your PMI intervals, driver hours, licence checks, maintenance records, training, defect reporting, and forward planning?
If the answer is ‘no one’, or ‘I don’t really know’, then make changes now.
This is a ticking time bomb.
· Get an independent auditor in.
· Find out what’s missing.
· Take immediate steps to become compliant.
Because once the Traffic Commissioner is involved, you’re not having a conversation, you’re on a one-way street to sanctions, curtailment, or revocation. And once your licence is gone, everyone is out of a job and getting a new operator licence is a long a difficult process.
If this post makes you feel uncomfortable, it probably should. But the good news is, it’s never too late to start making changes. If you act today, it serves two vital purposes.
Firstly, you start the process of regaining control and building proper compliance systems that protect your licence and your business.
Secondly, if you do find yourself in front of a Traffic Commissioner, you’ll have something to show them, evidence that you recognised the issues and took proactive steps to fix them. That matters. Traffic Commissioners take notice when operators acknowledge a problem and take responsibility. It can make the difference between a warning…or a revocation.