Agiliton
Sector obligation map

Mandatory training obligations in transport and logistics

4 training duties across 4 instruments binding Transport & Logistics, plus 10 that bind you whatever your sector — statute, rulebook, statutory guidance and licence conditions. Every one traced to its clause, its date and its published source, and each one labelled with what makes it a training duty.

JurisdictionUnited Kingdom
Built2026-08-11
Training duties14
Instruments12
Verified14 of 14
Every entry traced to a published clause

The duty everyone calls yours belongs to your drivers. What belongs to you is a criminal offence.

Driver CPC is one of the very few UK training requirements with a hard number attached — 35 hours in every five-year cycle. It is also the one most often assumed to sit with the operator. It does not: regulation 9(4) puts it on the driver personally.

What sits with you is regulation 10(2), and it is not a duty to train. It is an offence to cause or permit an out-of-CPC driver to drive. An operator who funds every hour of training and does not check expiry at despatch commits it. An operator who funds nothing and checks every card does not.

The obligations

Each clause carries a label saying why it is a training duty. Where the instrument does not use the word, we cite the guidance or the case that makes training the way you discharge it. Where we cannot cite anyone, it is not listed as a training duty at all.

says trainThe instrument itself requires training, instruction or CPD.
competenceThe instrument requires competence, qualification or knowledge. Training is the usual means; the instrument does not name it.
guidanceThe binding duty is an outcome. Official guidance under the instrument names training as how it is discharged.
case lawThe binding duty is an outcome. Case law makes training the operative discharge.
ClauseWho must be trained or assessedWhat is requiredIntervalEvidence required
The Vehicle Drivers (Certificates of Professional Competence) Regulations 2007
Regulation 9(1) and 9(4), with regulation 4(1)
says train
named role — drivers of relevant vehicles (LGV/PCV) driving on a roadA CPC, national periodic CPC or Swiss CPC "is valid for a period of five years beginning with the relevant day" (9(1)). A periodic CPC is obtained by completing 35 HOURS of periodic training within that cycle. Quoted, 9(4): a person to whom the Regulations apply "is not permitted to drive a relevant vehicle on a road unless the person holds a valid CPC, national periodic CPC or Swiss CPC", or has completed a national return to driving course within the preceding year.35 hours per 5-year cycleA driver qualification card issued by the competent authority. Under regulation 7(1) the APPROVED TRAINING CENTRE, not the employer, must notify each completion to the authority and pay a fee of £1.25 per course hour — so the authoritative record of a driver's periodic training sits with the regulator, not in the operator's LMS.
The Railways and Other Guided Transport Systems (Safety) Regulations 2006
Regulation 24(1) and 24(2), with regulation 23(1)
competence
named role — any person under the controller's management, supervision or control who carries out safety critical work. Expressly EXCLUDING a person who is receiving practical training in a safety critical task.Quoted, 24(1): the controller "shall, so far as is reasonably practicable, ensure that a person under his management, supervision or control, with the exception of where that person is receiving practical training in a safety critical task, only carries out safety critical work where— (a) that person has been assessed as being competent and fit to carry out that work following an assessment by an assessor; (b) there is an accurate and up to date record in writing of that person's competence and fitness which references any criteria for determining competence and fitness against which that assessment of competence was made; (c) the record, or an accurate summary of the record ... is available for inspection, on reasonable request, by any other controller of safety critical work or any operator who may be affected by any safety critical work carried out ... by that person ...; and (d) there are in place suitable and sufficient arrangements for monitoring the competence and fitness of that person." 24(2) requires the controller to "without unreasonable delay review any person's competence or fitness assessment where— (a) they have reason to doubt the competence or fitness of a person ...; or (b) there has been a significant change" in the relevant matters. 'Assessor' is defined at 23(1) as a person competent to make an impartial and objective assessment of another's competence or fitness.No interval. Instead a MONITORING duty (24(1)(d)) plus a trigger-based REVIEW duty (24(2)) on doubt or significant change.EXPRESS AND PORTABLE. 24(1)(b) requires an accurate, up-to-date WRITTEN record that references the criteria the assessment was made against; 24(1)(c) requires that record, or an accurate summary of it, to be available for inspection by ANY OTHER controller or affected operator on reasonable request.
Goods Vehicles (Licensing of Operators) Act 1995
Section 13A(3), with Schedule 3 paragraphs 13 and 14A
competence
named role — the transport manager, or the operator personally if an individual who is professionally competentQuoted, 13A(3): "The second requirement is that the traffic commissioner is satisfied that the applicant— (a) is an individual who— (i) is professionally competent (as determined in accordance with paragraph 13 of Schedule 3), and (ii) has designated a suitable number of individuals ... who satisfy the requirements set out in paragraph 14A(1) and (2) of Schedule 3, or (b) if the applicant is not an individual, or is an individual who is not professionally competent, has designated a suitable number of individuals who satisfy the requirements set out in paragraph 14A(1)" and (2) of that Schedule.None — a continuing condition of holding the licence, not a periodic one.Satisfaction of the traffic commissioner. The detailed criteria sit in Schedule 3 and are NOT quoted here — see verification note.
Directive 2003/59/EC on the initial qualification and periodic training of drivers of certain road vehicles
Article 3(1), with Article 1
says train
named role — drivers within the Article 1 scopeQuoted, Article 3(1): "The activity of driving as defined in Article 1 shall be subject to a COMPULSORY INITIAL QUALIFICATION and COMPULSORY PERIODIC TRAINING. To this end Member States shall provide for: (a) a system of initial qualification..." Member States choose between a course-plus-test option and a test-only option. For the accelerated initial qualification under Article 5(5) the Directive sets a length of "35 hours, including two-and-a-half hours of individual driving", concluding with a test set by the competent authority.Initial qualification plus compulsory periodic training; the accelerated initial qualification is fixed at 35 hours including 2.5 hours individual driving.A Certificate of Professional Competence (CPC) issued under Article 6(1)(a).

Binds you whatever your sector

10 further obligations sit outside Transport & Logistics regulation and bind you as an employer or as a deployer of AI. They are the ones a sector-by-sector review misses, because nobody who reads only their own rulebook ever reaches them.

ClauseWho must be trained or assessedWhat is requiredIntervalEvidence required
EU AI Act (Reg (EU) 2024/1689)
Article 4 (AI literacy)
says train
defined population — quoted from the pre-amendment text: "their staff and other persons dealing with the operation and use of AI systems on their behalf"AS ENACTED: providers and deployers were to take measures to ensure, to their best extent, a sufficient level of AI literacy of their staff and other persons dealing with the operation and use of AI systems on their behalf, taking into account technical knowledge, experience, education and training, the context of use, and the persons on whom the systems are used. AS AMENDED from 2026-07-27 by the Digital Omnibus on AI: AI literacy remains an obligation on providers and deployers, but no specific or 'sufficient' level is mandated; the Commission and Member States take a stronger role in promoting AI literacy. The obligation on deployers of HIGH-RISK AI systems to ensure staff are trained for human oversight remains in place.none specifiednone specified
Article 26(2)
says train
named population — the natural persons assigned to exercise human oversightQuoted: "Deployers shall assign human oversight to natural persons who have the necessary competence, training and authority, as well as the necessary support."none specifiednone specified in this paragraph
Employment Rights Act 2025
Whole Act — training provisions at s.65 and related
says train
named role — trade union equality representatives, not the general workforceThe Act's training provisions concern whether a trade union equality representative has undergone sufficient training to carry on those activities, with notice requirements on the union and reference to a relevant ACAS or Secretary of State Code of Practice. It is not a mandatory workforce training duty of the kind the rest of this map records.none specifiedWritten notice from the trade union to the employer
Equality Act 2010
Section 109(4), with section 109(1)
case law
Allay (UK) Ltd v Gehlen [2021] UKEAT/0031/20 — stale or inadequate training defeats the s.109(4) 'all reasonable steps' defence, making training the operative discharge.
all staff — the defence turns on steps taken to prevent employees doing discriminatory actsAn employer is liable for anything done by a person in the course of their employment. Quoted from 109(4): "In proceedings against A's employer (B) in respect of anything alleged to have been done by A in the course of A's employment it is a defence for B to show that B took all reasonable steps to prevent A—(a) from doing that thing, or (b) from doing anything of that description."none specifiedThe employer must SHOW the steps taken. The burden sits with the employer.
UK GDPR
Article 24, read with Article 5(2)
guidance
UK GDPR Article 39(1)(b) — read at source 2026-08-12 — names staff training as an element of compliance with the Regulation: the data protection officer must "monitor compliance with this Regulation... including the assignment of responsibilities, awareness-raising and training of staff involved in processing operations, and the related audits". LIMIT OF THIS CITATION, stated plainly: Article 39 applies only where Article 37 requires a DPO to be appointed, so it does not by itself establish a training duty for every controller. It establishes that the Regulation treats staff training as part of compliance. The unconditional citation would be the ICO Accountability Framework, which has NOT been read — see not_yet_searched.
not specified — training is not expressly named in Article 24Quoted: "the controller shall implement appropriate technical and organisational measures to ensure and to be able to demonstrate that processing is performed in accordance with this Regulation." Those measures must be reviewed and updated where necessary, and are to include appropriate data protection policies where proportionate to the processing activities. Article 5(2) supplies the accountability principle itself: "The controller shall be responsible for, and be able to demonstrate compliance with, paragraph 1" — that is, with all six data protection principles: lawfulness, fairness and transparency; purpose limitation; data minimisation; accuracy; storage limitation; and integrity and confidentiality.measures to be reviewed and updated where necessary — no intervalThe controller must be able to DEMONSTRATE compliance. This is the accountability limb.
The Regulatory Reform (Fire Safety) Order 2005
Article 21, with articles 3 and 6
says train
all staff — quoted: "his employees"Quoted, 21(1): the responsible person "must ensure that his employees are provided with adequate safety training (a) at the time when they are first employed; and (b) on their being exposed to new or increased risks because of" transfer or change of responsibilities, new or changed work equipment, new technology, or a new or changed system of work. 21(2): that training must "(a) include suitable and sufficient instruction and training on the appropriate precautions and actions to be taken by the employee in order to safeguard himself and other relevant persons on the premises; (b) be repeated periodically where appropriate; (c) be adapted to take account of any new or changed risks; (d) be provided in a manner appropriate to the risk identified by the risk assessment; and (e) TAKE PLACE DURING WORKING HOURS."Trigger-based, not periodic: on first employment AND on each of four listed changes. "Repeated periodically where appropriate" — no interval stated.none specified in the article
The Management of Health and Safety at Work Regulations 1999
Regulation 13(2), with 13(1) and 13(3)
says train
all staff — every employee, on recruitment and again on each triggering changeQuoted, 13(2): "Every employer shall ensure that his employees are provided with adequate health and safety training— (a) on their being recruited into the employer's undertaking; and (b) on their being exposed to new or increased risks because of— (i) their being transferred or given a change of responsibilities within the employer's undertaking, (ii) the introduction of new work equipment into or a change respecting work equipment already in use within the employer's undertaking, (iii) the introduction of new technology into the employer's undertaking, or (iv) the introduction of a new system of work into or a change respecting a system of work already in use within the employer's undertaking." 13(1) separately requires the employer, "in entrusting tasks to his employees, [to] take into account their capabilities as regards health and safety."No fixed interval. The duty is TRIGGER-BASED — on recruitment, and on each of the four changes listed in 13(2)(b).Not specified in the regulation itself.
Health and Safety at Work etc. Act 1974
Section 2(2)(c), with section 2(1)
says train
all staff — scoped by what is 'necessary to ensure' their health and safetyQuoted, s.2(2)(c): the employer's general duty extends in particular to "the provision of such information, instruction, training and supervision as is necessary to ensure, so far as is reasonably practicable, the health and safety at work of his employees." This is the primary-legislation parent of the MHSWR reg 13 duty. Note the double qualifier: training is owed only so far as it is BOTH 'necessary to ensure' health and safety AND 'reasonably practicable'.None. The measure is necessity, not interval.Not specified in the section.
Council Directive 89/391/EEC (the Framework Directive) on the introduction of measures to encourage improvements in the safety and health of workers at work
Article 12(1) and 12(4)
says train
all staff — 'each worker'Quoted, 12(1): "The employer shall ensure that each worker receives adequate safety and health training, in particular in the form of information and instructions specific to his workstation or job: — on recruitment, — in the event of a transfer or a change of job, — in the event of the introduction of new work equipment or a change in equipment, — in the event of the introduction of any new technology. The training shall be: — adapted to take account of new or changed risks, and — repeated periodically if necessary." Quoted, 12(4): "The training referred to in paragraphs 1 and 3 MAY NOT BE AT THE WORKERS' EXPENSE... The training referred to in paragraph 1 MUST TAKE PLACE DURING WORKING HOURS."No fixed interval. Trigger-based on four named events, PLUS two standing qualities the UK implementation does not spell out as clearly: adapted to new or changed risks, and "repeated periodically if necessary".Not specified in Article 12.
Article 12(2)
says train
named population — workers from OUTSIDE undertakings and/or establishments engaged in work in your undertaking. Contractors, agency staff, visiting engineers, maintenance crews.Quoted in full: "The employer shall ensure that workers from outside undertakings and/or establishments engaged in work in his undertaking and/or establishment HAVE IN FACT RECEIVED appropriate instructions regarding health and safety risks during their activities in his undertaking and/or establishment."None — triggered by the outside workers being engaged in work in your undertaking.Not specified, but note the wording: the employer must ensure they "have in fact received" the instructions. That is a verification duty, not a provision duty — it is not discharged by having issued something.

Related duties — not training obligations

1 provisions that sit alongside the duties above without themselves requiring training. They are here because they are the ones most often mistaken for training duties, or most often missed when scoping them. We separate them rather than pad the count.

ClauseWho it concernsWhat is requiredIntervalEvidence required
The Vehicle Drivers (Certificates of Professional Competence) Regulations 2007
Regulation 10(2), with regulation 10(1) and 10(3)
related
Not a training duty — an offence of causing or permitting. Carried because it is the operator's actual liability behind the driver's duty.
n/a — this is a criminal offence of causing or permitting, not a duty to trainQuoted, 10(2): "A person who causes or permits another person to drive a relevant vehicle on a road in breach of regulation 4(1) or 9(4) is guilty of an offence." 10(1) makes the driver's own breach an offence. 10(3): liable on summary conviction to a fine not exceeding level 3 on the standard scale.n/a — the offence is committed on each occasion of causing or permittingNone specified. In practice the defence is knowing each driver's CPC expiry before despatch — a data problem, not a training-delivery one.

Where gaps commonly sit

The word “employer” does not appear in the Regulations at all

We searched the full revised text of the Vehicle Drivers (Certificates of Professional Competence) Regulations 2007 — around 134,000 characters — for an employer duty to provide, fund or record Driver CPC training.

“Employer” appears zero times.

Driver CPC is routinely sold to operators as their mandatory training obligation. On the Regulations it is their drivers’ qualification, and their own criminal exposure for despatching an unqualified one. Those are different problems with different solutions.

The authoritative record is not in your LMS

Under regulation 7(1) the approved training centre must notify each completion to the competent authority and pay a fee of £1.25 per course hour. The definitive record of a driver’s periodic training therefore sits with the regulator.

An internal completion report is a secondary source for a duty whose primary record is held elsewhere — and it is the primary record a driver takes with them when they leave.

A criminal offence answered by a data check, not a course

Regulation 10(3) sets the penalty at a fine not exceeding level 3 on the standard scale, on summary conviction, for each occasion of causing or permitting.

The control that prevents it is knowing every driver’s CPC expiry date before despatch. That is a data problem. No amount of training delivery answers it, which is why a well-run training function can sit alongside a live criminal exposure.

The dangerous-goods training duty is not in the regulations that impose it

CDG 2009 is where operators look for the ADR driver requirement and the Dangerous Goods Safety Adviser requirement. We read all 166,280 characters of it. Neither is there.

The instrument works by applying ADR, RID and ADN directly: a reference in the Regulations to a Part, Chapter or Sub-section is construed as a reference to that Part of ADR for road, RID for rail, ADN for inland waterway. Its own text points at “Sub-sections 1.8.3.7 to 1.8.3.16 (which relate to the training and examination system for safety advisers and the connected issuing and renewal of vocational training certificates)”.

So the duties are real and they are in ADR Chapter 1.8.3 (safety advisers) and Chapter 8.2 (drivers) — documents that are not on legislation.gov.uk. The only training text inside the SI itself concerns radiation emergencies for class 7 goods. We have declared ADR unread rather than summarise it.

The competence record has to be legible to someone else

ROGS regulation 24 requires a written record of a person’s competence and fitness that references the criteria the assessment was made against — and then 24(1)(c) requires that record, or an accurate summary, to be available for inspection by any other controller of safety critical work or any operator who may be affected.

Almost no other UK duty requires your competence evidence to be readable by a third party. It means a pass mark is not enough; the record has to show what was assessed. And the duty binds the controller of the work rather than the employer, so on a contracted site the person who owes it may not be the person paying the wages.

Coverage

This map states what it did not check as well as what it did. A map that quietly omits its own gaps is worth less than one that marks them.

Searched and found

4 obligations across 4 instruments, each read directly from the published source on 2026-08-11.

Searched and found nothing

Recorded because “we searched and found nothing” is a different fact from “we did not search”.

  • The Vehicle Drivers (Certificates of Professional Competence) Regulations 2007 — NO EMPLOYER TRAINING DUTY EXISTS IN THIS INSTRUMENT. The word "employer" appears ZERO times in the whole instrument (searched 2026-08-11 across the full revised text, ~134,000 characters). The duty to hold a valid CPC is on the driver personally (reg 9(4)); the operator's exposure is the offence of causing or permitting under reg 10(2). This matters commercially: Driver CPC is routinely presented to transport operators as their mandatory training obligation, and as a matter of the Regulations it is not — it is their drivers' qualification and their own criminal exposure for despatching an unqualified one. NOT checked: whether an employer duty arises elsewhere, e.g. under operator licensing or health and safety law — recorded as not searched rather than as absent.
  • The Carriage of Dangerous Goods and Use of Transportable Pressure Equipment Regulations 2009 (S.I. 2009/1348) — WHOLE INSTRUMENT (166 — THE TRAINING REQUIREMENTS ARE NOT IN THIS INSTRUMENT — IT APPLIES THEM BY REFERENCE, AND THAT IS THE POINT. CDG 2009 works by applying ADR (road), RID (rail) and ADN (inland waterway) directly: reg 2(2) provides that a reference in the Regulations to a 'Part', 'Chapter', 'Section' or 'Sub-section' is to be construed as a reference to that Part of ADR for road carriage, RID for rail, and ADN for inland waterway. The instrument's own text points at "Sub-sections 1.8.3.7 to 1.8.3.16 (which relate to the training and examination system for safety advisers and the connected issuing and renewal of vocational training certificates)". The 7 in-text training references that DO appear are confined to radiation-emergency provisions for class 7 (radioactive) goods — emergency plans, identifying employees who may receive an emergency exposure, and training them in radiation protection. CONSEQUENCE: an operator reading the SI expecting to find the ADR driver training requirement, or the Dangerous Goods Safety Adviser requirement, will not find it there. Those live in ADR itself — Chapter 1.8.3 for safety advisers and Chapter 8.2 for drivers. SCOPE: ADR, RID and ADN are international agreements not published on legislation.gov.uk and have NOT been read. This negative says where the duty is, not that there is none.
Not searched

Their absence is not evidence that they contain no training duty.

  • Working Time (Road Transport) Regulations 2005 and drivers' hours rules — for any training limb
  • Operator licensing (Goods Vehicles (Licensing of Operators) Act 1995) — transport manager professional competence
  • Rail: Personal Track Safety (PTS) and ROGS 2006 competence management
  • Aviation and maritime crew training regimes — outside the road-transport pool measured here
  • 🔴 ADR (the European Agreement concerning the International Carriage of Dangerous Goods by Road) — Chapter 1.8.3 (dangerous goods safety adviser training and examination) and Chapter 8.2 (driver vocational training certificates). These are where this sector's dangerous-goods training duties ACTUALLY live; CDG 2009 applies them by reference. ADR is not published on legislation.gov.uk and is UNREAD. Highest-value remaining gap for this sector.
  • Goods Vehicles (Licensing of Operators) Act 1995 Schedule 3 paragraphs 13 and 14A — the substance of 'professionally competent'. The s.13A(3) cross-reference is recorded; the Schedule itself is unread.
  • ROGS 2006 Part 4 regulations 23, 25 and 26 — only regulation 24 has been read. Reg 25 (fatigue) and reg 26 are unexamined.
  • Directive (EU) 2018/645 — amends 2003/59/EC on driver initial qualification and periodic training. UNREAD; it post-dates the text recorded here and may change the periodic training requirements.
  • Regulation (EC) 561/2006 (drivers' hours) and Directive 2002/15/EC (road transport working time) — unread for any training or competence limb.

Sources

Thirty minutes, on your own material

Ten minutes on where your obligations actually sit. Fifteen watching a module built live from your own source documents. Five on whether there is a next step. Nothing to prepare and nothing to send beforehand.

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