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ERRU Penalty Points and Licence Suspension: What EU Transport Companies Need to Know

By 7 April 2026No Comments9 min read
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Something changed in late 2025. A haulier lost its operating licence not from a single catastrophic failure, but from accumulated penalty points in the EU’s ERRU system. The first known case of its kind. If you run a European transport operation and you’re still treating ERRU as a background compliance concept, this is the article to read.

What ERRU actually is

The European Register of Road Transport Undertakings is a centralized database linking the national registers of road transport operators across all 27 EU member states. It was established under Regulation (EC) No 1071/2009, the legislation that governs access to the occupation of road transport operator.

The concept solves a real problem. Before ERRU, a company that lost its licence in one country could continue operating through subsidiaries or reregistration elsewhere. National enforcement agencies had no reliable mechanism to check a foreign operator’s compliance history across borders. ERRU closes that gap.

Every licensed road transport operator in the EU has a record in the system. Every serious infringement recorded by any national authority feeds into that record, regardless of where in the EU the violation occurred.

How it works in practice

The database operates as a network of national registers rather than a single central server. Each member state’s competent authority manages its own data and exchanges records with others automatically. A Romanian company caught with a tachograph violation in Germany will see that infringement show up in the Romanian competent authority’s view of the company’s ERRU profile.

How the penalty point system works

Not every traffic fine registers in ERRU. The system specifically tracks infringements against Regulation (EC) No 561/2006 (driving and rest times), Regulation (EU) No 165/2014 (tachographs), and related transport legislation. Each infringement generates a corresponding number of penalty points for the transport operator — not just the driver involved.

This is the part that catches companies off guard. A driver’s conviction doesn’t stay with the driver. It follows the company that employed him. The operator accumulates the points regardless of whether the driver is still employed there.

Each company has a maximum allowed threshold, calculated proportionally based on fleet size or the number of certified copies of its operating licence. Larger fleets get a higher absolute threshold, but the ratio is fixed. Once the threshold is crossed, the competent authority of the home member state is required to open a procedure that can lead to loss of good repute, licence suspension, or full withdrawal.

Two-year clock

Penalty points remain active in ERRU for two years from the date the underlying sanction becomes final. They cannot be removed early, and a pattern of infringements spread over 18 months can accumulate faster than you think.

The three infringement tiers

ERRU classifies every relevant infringement into one of three categories. The tier determines the point score assigned, and point scores are not equal across tiers.

Tier 1

Serious Infringements (SI)

Baseline violations. A driver exceeding daily driving time by a moderate margin. A delayed tachograph data download. The lowest point score per incident.

Tier 2

Very Serious Infringements (VSI)

Exceeding maximum driving time significantly, failing mandatory rest periods, or inadequate record-keeping at a level that suggests systematic disregard.

Tier 3

Most Serious Infringements (MSI)

Tachograph manipulation, deliberately falsified records, systematic driving time violations. Maximum point scores. In most member states, automatic notification to the competent authority.

The practical implication: a company can reach its threshold through a large number of SI violations just as easily as through a smaller number of MSI violations. Volume matters, not just severity.

Why the first licence suspension matters

Trans.info reported the first known case of a transport operator losing its licence through ERRU point accumulation in late 2025. For years, operators could reasonably wonder whether ERRU enforcement was theoretical or operational in practice. Regulators had the tools. It was unclear how aggressively they intended to use them.

That question is now answered.

The case establishes three things that weren’t conclusively proven before. The data exchange between national registers works reliably across borders. Competent authorities are actively monitoring accumulated scores and acting when thresholds are crossed. A pattern of infringements across multiple EU countries catches up with an operator regardless of which member state is home.

For international hauliers running regular routes through multiple countries — which is the normal situation for most significant EU operators — this is exactly the enforcement scenario the system was designed to address.

The violations that generate the most points

Based on inspection data from enforcement bodies across EU member states, four categories consistently generate the highest volume of ERRU-relevant records.

Tachograph data downloads

Regulation (EU) No 165/2014 requires vehicle units to be downloaded at least every 90 days, and driver cards every 28 days. Missed downloads are among the most frequently recorded infringements. Partly because they are straightforward to detect during roadside checks and depot inspections, and partly because many fleets still rely on manual tracking that fails quietly.

Driving time and rest violations

The 9-hour daily driving limit (extendable to 10 hours twice per week), the 45-hour weekly rest requirement, and the 4.5-hour continuous driving limit before a mandatory 45-minute break are all monitored. Isolated violations by individual drivers read very differently to inspectors than a fleet-wide pattern. The latter triggers much faster escalation.

Tachograph manipulation

This lands in MSI territory. Magnet use, calibration tampering, or systematic falsification of records generates the maximum point scores. In practice, this is rarely a surprise infringement — it’s a choice that catches up with operators eventually, because the audit trail exists in the data.

Overloading

Technically separate from tachograph regulation, but recorded through the same enforcement framework and feeding into the ERRU risk profile. Worth treating as an ERRU concern, not just a roadside fine.

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Good repute: the stake behind the points

Licence suspension gets most of the attention, but good repute is the underlying legal concept that makes the ERRU system consequential.

Under Regulation (EC) No 1071/2009, a transport operator must hold good repute to maintain its licence. Good repute is assessed at both company level and transport manager level. If a company loses good repute, both the licence and the transport manager’s Certificate of Professional Competence (CPC) can be affected.

Good repute doesn’t automatically recover when penalty points expire. A company that has lost it must apply for rehabilitation, and the process varies by member state. In some jurisdictions, rehabilitation requires a waiting period plus demonstrated corrective action. In others, it sits at the discretion of the competent authority.

A transport manager who loses good repute can be declared unfit to manage transport operations in the EU. That declaration goes into ERRU and is visible to competent authorities in other member states. Moving country and reregistering does not clear it.

What prevention actually looks like

The enforcement logic of ERRU is straightforward: catch repeated violations, escalate consequences for persistent offenders, prevent licence abuse across borders. The implication for transport operators is that compliance can no longer be treated as a reactive activity.

Responding to inspection findings after they occur, paying fines and moving on — that approach worked when enforcement was fragmented. It does not work when every infringement contributes to a running total that follows the company across 27 countries for two years.

What actually reduces ERRU risk is visibility into operational data before it becomes an infringement record. Tachograph data, downloaded on schedule and analyzed systematically, shows which drivers are pushing against driving time limits, which vehicles have download intervals approaching the 90-day mark, and which fleet-level patterns might attract attention at a roadside check.

Frequently asked questions

Do ERRU penalty points follow the company or the driver?

Both. Infringements committed by drivers are recorded against the operator that employs them, not just the individual driver. Drivers can also accumulate records affecting their own professional standing and driver card status. An operator cannot avoid ERRU consequences by arguing the driver was responsible.

Can penalty points be removed before the two-year period expires?

No. Points remain active for two years from when the underlying sanction becomes final. The company can contest the underlying infringement through the relevant national legal process, but confirmed sanctions feed into ERRU automatically and cannot be administratively removed.

Does ERRU apply to cabotage operations?

Yes. Foreign operators conducting cabotage in an EU member state are subject to the same regulations. Infringements recorded during cabotage operations contribute to the operator’s ERRU profile in their home member state.

What happens to a transport manager who moves to a new company?

The transport manager’s individual good repute record in ERRU follows them regardless of employer. A new employer taking on a transport manager with an adverse ERRU record needs to know that. A declaration of unfitness to manage transport operations is visible to competent authorities in all member states.

Is there a public way to check a company’s ERRU status?

No public-facing search tool exists. Access to ERRU records is restricted to national competent authorities and, in some member states, to the licensed operators themselves for their own records. If you operate in a country where self-access is available, requesting your own record is a reasonable first step in understanding your current exposure.

How do threshold calculations work for fleet size?

The maximum allowed threshold is calculated proportionally to the number of vehicles in the licensed fleet. A larger fleet has a higher absolute threshold but the same ratio of points-per-vehicle applies. This means that growing your fleet does not provide a structural advantage in terms of tolerance — the exposure scales linearly.

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