lorry-lifeShiftOwt8 min read

HGV cab documentation at the roadside: the 28-day record, the Article 35 printout procedure, and what you write when the card isn't in the slot

Got stopped at M6 J18 with everything in order — except I hadn't annotated the start-of-day printout correctly. Two signatures, two time entries, and knowing which ones matter is what Article 35 is about.

HGV cab documentation at the roadside: the 28-day record, the Article 35 printout procedure, and what you write when the card isn't in the slot

The papers you're asked for, in the order they're asked for

Get waved into a DVSA check site and the sequence usually goes like this: cab door open, licence first, card second. If the card's inserted in the tachograph, the officer will download it there and then using a handheld interrogation device or through the vehicle head unit. If the card isn't in — because it's damaged, missing, at home in your other jacket — that's when the printout conversation starts.

Most drivers know they need their licence and their card. Fewer have thought carefully about what happens when one of those isn't available, or what they need to be able to produce beyond the basics. This post covers what you're legally required to carry, what records you need to be able to show, and what goes on a printout when the card can't do the recording for you.

The driving licence

Section 164 of the Road Traffic Act 1988 gives a police constable or a DVSA examiner the power to require you to produce your licence. You must produce it on demand or produce it at a police station within seven days. In practice at a roadside check, the officer will want to see it there and then.

Your licence must be current, must include the relevant Category C or C+E entitlement, must not have expired or been revoked, and must be for you — not an identical name that happens to match. Officers have access to DVLA records and will often cross-reference the licence details with the tachograph card data. If the name on the card and the name on the licence don't match exactly, that's a question that needs answering.

For LGV licence holders, if your licence shows any restriction codes — corrective lenses, for example — you need to be compliant with those too. An officer finding a driver who has a restriction code requiring glasses but isn't wearing any isn't going to let that slide.

The driver card

The driver card must be inserted in card slot 1 of the tachograph whenever you're driving a vehicle in scope of EU 561/2006 or the Regulation (EU) 165/2014 tachograph rules. This is the card that records your activity — drive, rest, work, availability — and that DVSA will download and analyse at the roadside or at an operator premises inspection.

The card must be yours. One card per driver. You must not use anyone else's card, and you must not knowingly drive with the wrong card in the slot. If the wrong card is in when you pull away, the device is recording your driving against someone else's identity — that's a falsification offence, not a minor technical issue.

The 28-day record requirement

Article 36 of Regulation (EU) 165/2014 (retained in UK law) sets out what you must be able to produce for inspection. The standard requirement: records for the current day and the previous 28 calendar days. From April 2025, for vehicles in certain categories under the amended regulation, this extends to 56 days — if you're unsure whether the 56-day extension applies to your vehicle, check with DVSA directly.

What this means in practice: if you're stopped today, the officer can ask to see evidence of your activity for the last 28 days. Most of that will be on your card — digital tachographs store approximately the last 28 days of driver activity data on the card itself. If the officer downloads the card, they get that data. If the card is clean and complete, the download covers the requirement.

Problems arise when there are gaps in the card data. Days when you drove on a different card (it happens — expired card situation, card mismatch). Days when you drove a vehicle not fitted with a digital tachograph and used analogue record sheets. Days when you were on manual records because the vehicle unit failed. All of those need to be covered by the appropriate physical record.

Analogue record sheets from within the 28-day window need to be with you in the cab. Not at home. Not at the operator's office. With you. If you drove on an analogue sheet three weeks ago and it's sitting in a pile on your kitchen table, that's a gap in your producible record that you can't explain at the roadside.

When the card isn't in — the Article 35 printout procedure

This is the most misunderstood part of the documentation rules. Article 35 of Regulation (EU) 165/2014 covers what happens when a driver card is not available for the journey — typically because it's been lost, stolen, damaged, or is waiting to be replaced after the five-year validity period expired.

The requirement is two printouts, properly annotated:

Start-of-day printout: printed from the vehicle unit at the beginning of the daily working period. The driver must write on the printout: name, driver card number or driving licence number, and a signature. Must also enter the time periods covering the activities since the last daily rest that aren't captured by the device — anything you did before getting in the vehicle for this shift that should be on the record (other work, availability, etc.).

End-of-day printout: printed from the vehicle unit at the end of the daily working period. Same identification details — name, card or licence number, signature. Plus a manual note of any time periods not automatically recorded: activities after you stopped the vehicle but before you started your rest period.

The printout itself comes from the vehicle unit tachograph — the head unit in the dash, not a separate printer you might have in the cab for delivery paperwork. The button sequence varies by tachograph model; on a Stoneridge SE5000 or a VDO DTCO it's a different sequence, but most drivers working with a specific vehicle will know their head unit's menu.

What you write and why it matters

The annotation on a printout is a manual record. It needs to be legible, accurate, and signed. This sounds obvious until you're doing it in a car park at 03:30 with a biro that's running out of ink.

Name: full name as it appears on your licence and card.

Card or licence number: if you don't have the card (it's lost), your driving licence number. If you have the card but can't insert it (slot damaged), the card number.

Signature: your actual signature. Same one as on your licence. Not an illegible scrawl and not a printed block capital.

Time entries: any periods since the last daily rest that the tachograph wasn't recording — because you hadn't started the vehicle yet, because you were doing pre-trip checks, because you were doing paperwork at the yard before pulling out. These go on the start-of-day printout. At the end of the day, any periods after you stopped the vehicle and before you started rest — post-shift yard work, loading, security gates.

The reason this matters: a roadside stop where the card isn't in the slot but the printout is correctly annotated and signed is a manageable situation. A roadside stop where there's no card, no printout, and no explanation is a falsification risk. The officer doesn't know whether you've been driving undocumented — and the safe assumption at the roadside is not favourable to you.

The missing-card procedure revisited

The full missing-card procedure — Article 29 printout approach, the 7-day DVLA replacement timeline, and what happens when the card is genuinely lost rather than forgotten — is covered in more detail in the lost card post. The short version: you can use the printout procedure for up to 15 calendar days while waiting for a replacement card. Beyond that, you shouldn't be driving under the same lost-card justification without a replacement or a reasonable explanation.

The gap between 'carry' and 'produce'

There's a distinction in the regulation between what you must carry with you in the cab and what you or your operator must be able to produce within a reasonable period. For the 28-day window, the expectation at a roadside stop is immediate production — you should have the records with you.

Operators are required to keep tachograph data and records for a longer period — 12 months minimum, and 24 months if tachograph records are the primary source of working-time records for WTD purposes. But that operator-held archive doesn't help you at a roadside check. What the officer asks for, you need to have on you or in the vehicle.

One situation that catches drivers: a partial week worked at the start of the 28-day window on a different type of vehicle, or for a different operator, that requires manual record sheets the driver has handed in. If the operator's copy is the only copy, and the operator isn't reachable at 22:00 on a motorway services, you have a gap you can't explain until morning. Keep your own copies of anything you've handed in that falls within the 28-day window.

The pre-drive documentation check

Before you pull out of the yard:

  • Driving licence: with you, valid, correct categories, any restrictions complied with
  • Driver card: with you, inserted in slot 1 before you move
  • Analogue sheets: any from the last 28 days (if applicable) in the cab
  • Manual records: any printouts from card-malfunction periods within the 28-day window

If you're starting a shift without your card — it's at home, the five-year validity expired and the replacement hasn't arrived — do the start-of-day printout from the vehicle unit, annotate it correctly, and keep it with you. Do the end-of-day printout the same way. These are your record for that day.

If you've been carrying analogue sheets because you've been running a vehicle under GB domestic rules and then switch to a tachograph-fitted vehicle mid-week, make sure the analogue sheets are in the cab — not in the glovebox of the domestic-rules vehicle you left at the yard.

None of this is complicated. It's logistics. The roadside stop where documentation is missing is always the one where you'd have been fine if you'd just taken an extra five minutes at the yard gate.

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