Many transport news websites and other experts compete to provide information on the “Mobility Package” topic, aiming to help fellow hauliers with matters related to legislation, fines, exemptions, application deadlines, etc.
Theory is one thing — practice is what gets us!
Hauliers often spend hours reading seemingly endless pages about the “Mobility Package,” and most of the time the following practical questions come to mind:
- What happens if I get inspected?
- What documents do I need to prepare?
- In which countries have inspections already been carried out?
- How does an inspection work?
Most of the time, they’re left without a concrete answer…
Mobility Package inspections
Since the Mobility Package came into force on February 2, 2022, based on information from our haulier partners, we have analyzed how each country has enforced these measures.
So far, we have gathered a great deal of information, which you’ll find briefly summarized in this article.
As of 10.10.2022, based on the data collected, the countries that used the IMI portal the most to carry out transport inspections were:
- Denmark
- France
- Austria
Good to know — inspections are based both on prior roadside checks and on random selection from the IMI certificates completed and registered on the platform.
Hauliers that were subjected to the most Mobility Package inspections came from the following countries:
- Romania
- Poland
- Hungary
- Bulgaria
Mobility Package — Top 5 documents most frequently requested during inspections:
- CMR/ transport documents;
- Data recorded by the tachograph;
- Employment contract;
- Pay slip;
- Proof of payments;
- IMI posting declarations;
- A1 form;
- Tachograph (on paper — for vehicles without a tachograph, e.g. vans);
For example, France has tightened roadside inspections regarding compliance with driving time regulations: drivers of vehicles up to 3.5 tons, including foreign drivers, must record their working and rest time while on French territory.
This must be done from the moment they enter the country until they leave it.
Working time records must be kept in a special register created for this purpose (Livret individuel de contrôle sur Carte de Control).
If a driver does not have an Individual Control Book or another document confirming working time, France will apply a penalty of 135 EUR (class 4 offense). This amount may be reduced to 90 euros or increased up to 750 euros.
Mobility Package — watch out for oversights…
Unfortunately, we have come across many hauliers who avoid preparing the appropriate documentation in case of an inspection, and the reason is simple: “I’ve never been inspected, so why waste time and money getting these documents?”.
It is worth noting that foreign enforcement authorities, whether in Austria, Germany, France or Italy, are starting to step up inspections and to severely penalize “unprepared” hauliers.
Recommended documents when driving on European roads
Based on our experience and expert recommendations, it’s a good idea to keep the following documents on board the vehicle in case of an inspection:
- Employment contract (translated into the language of the country being transited);
- The CMR;
- IMI declaration;
- Macron certificate (where applicable);
- A1 form;
- Tachograph records (on paper) for vehicles without a tachograph;
- Documents required for any driver: (ID, driver’s license, required certificates);
Questions and answers — Mobility Package 2022
What documents must the driver have during a roadside inspection under the Mobility Package?
During an inspection, the driver may typically be asked for the CMR, the IMI declaration, the A1 form, the employment contract, personal documents and tachograph records.
Is the IMI declaration mandatory and when must it be completed?
Yes, the IMI declaration is mandatory for drivers who fall under the posting rules and must be completed no later than the start of the posting period.
Does the A1 form have to be on board the vehicle?
Yes, the A1 form is a mandatory on-board document for trips covered by the rules imposed by the Mobility Package. That’s why not having it can quickly complicate an inspection, even if the rest of the documents are in order.
What do authorities check in the tachograph during a roadside inspection?
Authorities check the tachograph records, including driving times, rest periods and, where applicable, how border crossings were recorded.
The smart tachograph also helps because it can record border crossings and loading or unloading locations via GPS.
Does the driver have to record border crossings manually?
It depends on the type of tachograph used, and the European Commission recently clarified that drivers using a smart tachograph version 2 no longer need to enter border crossings manually, even if they have an older driver card.
That’s exactly why the generation of tachograph installed on the vehicle matters a great deal during an inspection.
How many hours can a driver legally drive under the Mobility Package?
The general rule is 9 hours per day, with the option of extending to 10 hours twice a week, plus a maximum of 56 hours per week and 90 hours over two weeks.
These limits are essential during an inspection because they are checked directly from the tachograph data
How often must the driver return home or to the company’s base?
The driver must return home or to the employer’s operational center at least once every four weeks for a regular rest period or to compensate for a reduced rest period.
This obligation is important because it is part of the general logic of working and rest time inspections.
Which drivers are not covered by the Posting Directive?
In general, these rules do not apply to drivers performing bilateral transport, transit without loading or unloading operations, and certain legs of combined transport, under the conditions provided by law.
This distinction is important because it determines whether or not the IMI declaration must be completed.
What changes for vehicles between 2.5 and 3.5 tons under the Mobility Package in 2026?
Additional obligations have been introduced for this category, including a transport license in certain situations and, for international transport or cabotage, the requirement to be fitted with a smart tachograph 2 from July 1, 2026.
In practice, light transport is getting closer and closer to the rules already applied to heavy vehicles.
What are the most common reasons for fines during inspections?
Among the most frequently cited risks are a missing posting declaration, failure to correctly record border crossings, and problems with tachograph records.
In other words, most problems arise when documents aren’t ready on board or when the tachograph data doesn’t support the actual type of transport operation.
