The DVSA Updated the Earned Recognition Operator Standards. What It Means for Your Next Audit

The DVSA made several changes to its Earned Recognition operator standards during 2025.

The key changes took place on three separate dates:

• 31 March 2025: the assessment criteria tables for HGV and PSV operator audits were updated.
• 27 May 2025: references to EU drivers’ hours rules were replaced with references to assimilated drivers’ hours rules.
• 16 June 2025: the Guild of British Coach Operators additional module became the PSV Private Hire module, with updated requirements.

These changes are now part of the current standards against which operators are assessed. They are not future proposals, and they do not only affect businesses applying to the scheme for the first time.

If you are already an Earned Recognition operator, your next periodic audit will be carried out against the standards in force at the time of the audit. That means documentation and processes that were accepted at your previous audit may need to be reviewed before your next one.

When did the standards change?

The DVSA publishes the official Earned Recognition standards for HGV and PSV operators on GOV.UK. The publication also records when changes were made and what was updated.

The three main updates covered by this article happened between March and June 2025.

31 March 2025: HGV and PSV assessment criteria were updated

On 31 March 2025, the DVSA updated the assessment criteria tables within both the HGV and PSV operator audit standards.

These tables are important because they set out:

• The standards an operator must meet
• How each area will be assessed
• What evidence an auditor may expect to see
• Whether a requirement is fully met, partly met or not met

The update did not replace the Earned Recognition scheme or create an entirely different audit. However, it means operators should work from the current assessment tables rather than relying on saved copies from an earlier audit.

The current standards are public documents designed to help both operators and auditors identify where requirements are met and where shortcomings need to be addressed.

27 May 2025: EU drivers’ hours references changed to assimilated rules

On 27 May 2025, references to EU drivers’ hours rules within the standards were updated to refer to assimilated drivers’ hours rules.

This was primarily a legal and terminology update following changes to how retained EU-derived law is described in Great Britain.

It does not mean that drivers’ hours controls have become less important or that operators can stop following established monitoring processes.

Operators must still be able to demonstrate effective management of areas such as:

• Driving time
• Breaks and rest periods
• Tachograph data
• Infringement reviews
• Driver debriefs
• Working time requirements where applicable
• Follow-up action and management oversight

The practical point for operators is that policies, training documents and written procedures may still contain outdated references to “EU drivers’ hours rules”.

Those documents should now be reviewed and updated where necessary so that they reflect the terminology used in the current DVSA standards.

16 June 2025: the PSV Private Hire module replaced the Guild of British Coach Operators module

On 16 June 2025, the Guild of British Coach Operators optional module became the PSV Private Hire module.

The change was more than a simple renaming exercise. The application documents and module standards were updated to reflect the new PSV Private Hire requirements.

The module remains additional to the main Earned Recognition operator standards. It is relevant to PSV operators seeking to demonstrate that they meet the additional requirements associated with private hire operations.

The DVSA confirmed the change through its updated additional-module application information, while the current PSV Private Hire standards set out the assessment and evidence required to achieve module status.

Operators that previously worked towards, or held, the Guild of British Coach Operators module should therefore check whether their documentation and evidence now meet the PSV Private Hire module requirements.

What do the changes mean for your next audit?

The changes do not mean that every Earned Recognition operator needs to rebuild its compliance system.

The main principles remain the same. Operators must still show that they have effective systems for managing vehicles, drivers, records, risk and regulatory responsibilities.

However, your next auditor will use the current standards, not the version used during your previous audit.

That creates three practical responsibilities:

• Make sure you are using the latest assessment criteria
• Update outdated terminology in your documents
• Check whether any additional modules relevant to your operation have changed

A previous audit pass confirms that your systems met the requirements at that point. It does not guarantee that unchanged documents will meet every current assessment criterion.

Review the current assessment tables

Operators should download the latest HGV or PSV standards from the official GOV.UK page and review the assessment criteria section by section.

Do not rely solely on a checklist retained from your last audit.

Look at:

• What the current standard requires
• How the criterion will be assessed
• What evidence is listed
• Whether your procedure still matches actual practice
• Whether the named person remains responsible
• Whether records are complete and readily available

The assessment tables provide a useful framework for an internal review because they show not only the required outcome, but also the types of evidence that may be considered during the audit.

Update drivers’ hours terminology

Search your policies and procedures for references to:

• EU drivers’ hours rules
• Retained EU law
• Older legislation or guidance
• Superseded internal document titles

The presence of older terminology does not automatically mean the underlying process is ineffective. However, outdated documentation can create uncertainty about whether the policy has been reviewed recently.

Where references are no longer current, update them to reflect assimilated drivers’ hours rules.

This may affect:

• Drivers’ hours policies
• Driver handbooks
• Training materials
• Infringement procedures
• Internal audit templates
• Compliance meeting documents
• Transport manager reports

Any update should be controlled properly. Record when the document was reviewed, what changed, who approved it and when the revised version came into effect.

Check whether procedures match daily practice

A well-written policy is not enough on its own.

The auditor will need evidence that the procedure is followed consistently.

For example, if your policy says tachograph infringements are reviewed within a set period, the records should demonstrate that this happens. If the procedure requires drivers to receive a debrief, the operator should be able to show the infringement, the explanation, the action taken and any follow-up.

The same principle applies across the audit.

You may need evidence of:

• Vehicle maintenance planning
• Safety inspection records
• Driver defect reporting
• Driver licence checks
• Tachograph analysis
• Infringement management
• Training and competency
• Internal audits
• Management reviews
• Corrective action
• KPI monitoring

The standards are designed to test whether compliance systems operate in practice, not simply whether the operator owns a collection of policies.

PSV operators should review additional modules carefully

The change from the Guild of British Coach Operators module to the PSV Private Hire module will not affect every PSV operator.

It matters particularly where an operator:

• Already holds an additional module
• Previously worked towards the Guild of British Coach Operators module
• Intends to apply for the PSV Private Hire module
• Uses module status to support contractual or commercial requirements

These operators should review the current PSV Private Hire module standards rather than assuming the previous requirements remain unchanged.

The module document explains the standards, assessment criteria and evidence needed to demonstrate compliance.

Do you need to change your systems immediately?

You should review your systems now, but that does not mean making rushed or unnecessary changes.

Start by comparing your current operation with the updated standards.

You may find that your systems already meet the requirements and only a small number of documents need updating. Alternatively, the review may identify missing evidence, unclear responsibilities or procedures that no longer reflect how the business operates.

The important point is to complete the review early enough to act before the formal audit.

Operators in the scheme must complete a periodic audit every two years using a DVSA-authorised audit provider. The DVSA may also request an earlier audit where concerns arise about performance.

A practical pre-audit checklist

Before your next audit, check that:

• You have downloaded the current HGV or PSV standards
• Your internal checklist reflects the assessment criteria updated on 31 March 2025
• Drivers’ hours documents use current assimilated-rules terminology
• Written procedures match what happens in practice
• Responsibilities and named personnel are current
• Records are complete, organised and accessible
• Internal reviews have been recorded
• Corrective actions have been followed through
• Relevant PSV additional-module requirements have been reviewed
• Key staff understand what evidence they may need to present

This should not be treated as a last-minute paperwork exercise.

The strongest preparation involves reviewing the system as a whole, identifying gaps and making sure the evidence shows consistent management over time.

Preparing for your next Earned Recognition audit

The 2025 changes were introduced on specific dates, but they now form part of the standards operators should be using.

To recap:

• 31 March 2025: HGV and PSV assessment criteria tables were updated.
• 27 May 2025: references to EU drivers’ hours rules were replaced with assimilated drivers’ hours rules.
• 16 June 2025: the Guild of British Coach Operators module became the PSV Private Hire module, with updated requirements.

If your previous audit took place before these dates, do not assume the same documents and checklist will be sufficient next time.

Download the latest standards, review your procedures against the current assessment criteria and leave enough time to address any gaps before the formal audit.

Total Compliance is a DVSA-authorised Earned Recognition audit provider for both HGV and PSV operators. Our auditors can assess your operation against the current standards and complete the formal audit required for entry to, or continued membership of, the scheme. To discuss your next Earned Recognition audit, call 0345 900 1312 or email info@totalcompliance.co.uk.