O-Licence Audit: What DVSA Actually Checks

Search "O-licence audit" and you get consultancies offering to do one for you. That may well be the right call — but before you buy an audit you should know what DVSA's own investigation actually looks at, because the structure is published and it is more specific than most people expect.

A DVSA maintenance investigation is scored section by section, and each section gets one of up to four outcomes. Knowing those two facts changes how you prepare: you are not trying to look generally competent, you are trying to avoid an "unsatisfactory" on any one of fourteen named areas.

General guidance, not legal advice. Investigation scope and reporting are set by DVSA and the Traffic Commissioners. Check current GOV.UK guidance and, where a visit has been notified to you, the correspondence you have received.

What the Investigation Is

DVSA states the position plainly: "The Driver and Vehicle Standards Agency (DVSA) carries out maintenance investigations of vehicle operator licence holders in England, Wales and Scotland." The purpose is narrow and worth quoting — "The investigations check if the operator has suitable systems, facilities and arrangements in place."

Systems, facilities and arrangements. Not whether your vehicles happen to be clean on the day. The examiner is assessing whether the operation produces compliance reliably, and the evidence for that is paperwork.

The output is a Maintenance Investigation Visit Report (MIVR), and DVSA "may report the outcome of a maintenance investigation to the Traffic Commissioners for Great Britain."

The Outcome Scale

Each question section on the MIVR is scored, and DVSA publishes the scale as a maximum of four outcomes:

"There is a maximum of 4 assessment outcomes for a question section: satisfactory – the operator does not need to take any action; mostly satisfactory – DVSA gives advice to the operator; unsatisfactory – operator action and explanation required; report to the Traffic Commissioners for Great Britain – operator action and explanation required"

Read that carefully. "Mostly satisfactory" costs you nothing but advice. The gap that matters is between mostly satisfactory and unsatisfactory, because at unsatisfactory you owe DVSA both an action and an explanation — and the top band routes the whole thing to a Traffic Commissioner.

The Fourteen Sections

DVSA states that "The maintenance investigation visit report has 14 question sections", and names them — number 9 carries two, one per vehicle type:

1. Operator legal entity
2. Condition of vehicles examined at the fleet check
3. Operating centre
4. Inspection and maintenance records
5. Driver defect reporting
6. Maintenance facilities and arrangements
7. Vehicle emissions
8. Wheel and tyre management
9. "Load security – heavy goods vehicles (HGVs) only"; "Public Service Vehicle Accessibility Regulations (PSVAR) – public service vehicles (PSVs) only"
10. Prohibition assessment
11. Security requirements
12. Previous reported shortcomings, conditions and undertakings
13. Transport manager/responsible person
14. Request for explanation response (where applicable)

Two of those are worth flagging for small operators because they are easy to lose without doing anything wrong.

Operator legal entity. The name on the licence must be the entity actually running the vehicles. Sole traders who incorporate and keep operating on the old licence fail this section, and it is not a paperwork quibble — the licence is held by a legal person, and the wrong person operating is operating without a licence.

Previous reported shortcomings, conditions and undertakings. Read the full title of section 12: it is not only about past findings. It is the section where an earlier promise and an earlier fix are both checked. If you have had an investigation before, or a prohibition, the examiner is looking at whether what you said you would fix is fixed — and an unresolved item from a prior visit reads far worse than a first-time finding.

The Records: What Has to Exist, and For How Long

This is where most preparation time should go. The retention periods come from three different places and they are not the same length.

Record	Minimum retention	Source
Safety inspection records	15 months	Guide to Maintaining Roadworthiness
Driver defect reports	15 months	Guide to Maintaining Roadworthiness
Drivers' hours records (tachograph)	Producible for 12 months	DVSA operator responsibilities guidance
Working time records	24 months	Senior Traffic Commissioner Statutory Document No. 3

The Guide to Maintaining Roadworthiness is direct: "Records of safety inspections must be kept for at least 15 months for all vehicles." It puts driver defect reports on the same clock in its own words — "Drivers' defect reports used to record any faults and rectification work must be kept for at least 15 months" — so that period does not depend on an undertaking being written on your particular licence, and electronic records are treated identically: they "must be available for 15 months, along with any record of repair." Our guide to the Guide covers the rest of what it expects from a maintenance system.

On drivers' hours, DVSA's guidance on the responsibilities of vehicle operators sets three duties that map straight onto what the examiner asks for: download driver cards "at least every 28 calendar days", download vehicle units "at least every 90 calendar days", and "Be able to produce records to enforcement officers for 12 months." The same guidance requires you to "Make regular checks of charts, manual records and digital data to ensure compliance." Our tachograph downloads guide covers the mechanics.

Working time is the one small operators most often miss, because it sits under a different instrument with a longer retention. Statutory Document No. 3 lists among a transport manager's duties "to ensure that all working time records are kept for a period of no less than 24 months and are made available upon request." Twenty-four months, not fifteen, not twelve.

The same document lists driving licence checking "(usually every 3 months)" — a small recurring task that produces an obvious paper trail when it is done and an obvious hole when it is not.

Defect Reporting Is Assessed as a Loop, Not a Form

Section 5 of the MIVR is driver defect reporting, and the failure mode is rarely the absence of a defect book. It is defects raised and never closed out.

The Guide to Maintaining Roadworthiness sets the front end: "A driver or designated responsible person must conduct a walkaround check of a vehicle prior to using the equipment on the public highway." It sets the back end too, and this is the sentence that catches people — "The transport manager or responsible person must have access to and review the completed safety inspection sheet or electronic record before the vehicle returns to service."

So the loop the examiner traces is: defect found → recorded in writing → rectified → signed off by someone competent → vehicle back in service. A stack of nil-defect sheets with no defects ever recorded across a year of operation invites the opposite question: is anyone actually checking? Our defect categories guide covers how DVSA grades what gets found.

Underneath all of it is the ownership question, which the Guide answers in one line: "As a user of vehicles, it is your responsibility to ensure that the vehicles you use are roadworthy."

Where an Adverse Report Goes

A poor MIVR does not itself remove a licence. It gives a Traffic Commissioner grounds to act, and the Goods Vehicles (Licensing of Operators) Act 1995, section 26 is where those grounds live. The ones an investigation typically engages:

• s.26(1)(b) — "that the licence-holder has contravened any condition attached to the licence"
• s.26(1)(e) — "that the licence-holder made, or procured to be made … a statement of fact that … was false, or a statement of expectation that has not been fulfilled"
• s.26(1)(f) — "that any undertaking recorded in the licence has not been fulfilled"
• s.26(1)(h) — "that since the licence was issued or varied there has been a material change in any of the circumstances of the licence-holder that were relevant to the issue or variation of the licence"

Paragraph (e) is the one operators underestimate. The inspection interval you wrote on your application is a statement of expectation. If your records show eight-week intervals against a six-week declaration, that is not a maintenance finding — it is an unfulfilled statement of expectation, and it is separately actionable from the maintenance itself. The public inquiry guide covers what happens if it gets that far.

A Fortnight's Preparation, In Order

If a visit is notified, work in this sequence rather than starting with the vehicles.

1. Reconcile the licence record against reality. Vehicles authorised versus vehicles operated, operating centre address, legal entity, transport manager. Discrepancies here are cheap to fix now and expensive to explain later.
2. Pull 15 months of inspection sheets and check they are complete, legible and signed off — including the return-to-service review. Missing sheets are worse than late ones; a gap looks like an inspection that never happened.
3. Check your declared inspection interval against what you actually did. If they diverge, decide now whether the answer is "we have corrected the interval" or "we are varying the declaration", and be able to show which.
4. Run the download-date list. Any driver card over 28 days or vehicle unit over 90 days gets downloaded before the visit, and the gap gets an explanation ready.
5. Trace three defects end to end. Pick them at random, follow each from the driver's report to the sign-off. If you cannot complete the loop on paper, that is your unsatisfactory section.
6. Check the working-time records reach back 24 months, not 15.
7. Assemble the driving licence check evidence for the last four quarters.

An external transport manager will normally run a mock version of exactly this, and several price audit days separately from the retainer — see our external transport manager cost guide for the published day rates. If you would rather see where the gaps are first, the free O-Licence Compliance Health Check walks the same ground, and the O-licence compliance checklist is the longer written version.

The Part Worth Internalising

The outcome scale rewards systems over heroics. An operator who produces fifteen months of ordinary, boringly complete records scores satisfactory. An operator who spends the fortnight before the visit reconstructing paperwork produces something that looks reconstructed, and section 14 — explanation responses — is where that conversation happens.

The work that passes an audit is the work that happens every week anyway. The audit just asks to see it.

If you want an independent audit on your own terms rather than DVSA's, the voluntary scheme works that way — see our DVSA earned recognition guide for what its audit checks.

Sources

• Vehicle operator maintenance investigations (MIVR guidance) — GOV.UK
• Guide to maintaining roadworthiness — GOV.UK
• Drivers' hours: responsibilities of vehicle operators — GOV.UK
• Senior Traffic Commissioner, Statutory Document No. 3: Transport Managers, version 17.0 (PDF) — GOV.UK
• Goods Vehicles (Licensing of Operators) Act 1995, section 26 — legislation.gov.uk