Ran a 12-vehicle fleet out of Coventry for two years on spreadsheets, printed tachograph reports, and one tacho analyser the previous TM had set up and I barely understood. Everything looked fine. Download logs were current. The weekly infringement email went out every Monday. Self-cert WTD forms came back signed, filed, and never thought about again.
Then DVSA arrived at the yard on a Tuesday morning and asked for the working-time records for the previous six months. Not just the tacho data. The full WTD working-time record — the rolling 17-week average, by driver.
I produced the tacho download logs. The infringement report was clean. But the WTD record — the actual 17-week rolling average calculation across twelve drivers — wasn't something I had on a single sheet I could hand over. It was buried across monthly tabs, self-cert forms, holiday records, and my own memory of which driver had been off sick in April.
Not a prohibition. Not even a formal written warning on the day. But the improvement notice covered WTD record-keeping specifically, and I spent three weeks rebuilding the whole system. That's when I stopped treating EU 561 and the WTD as the same problem.
What a spreadsheet does fine
Don't dismiss spreadsheets entirely. If you're disciplined, you can track the 28-day driver card download window, the 90-day vehicle unit download window, weekly driving hours by driver, and basic infringement categories. That's the core of EU 561/2006 compliance, and a spreadsheet handles it.
The 28 days for the driver card and 90 days for the vehicle unit — those are the download requirements under Regulation (EU) 165/2014, Article 10. Miss them and you've got a potential s.99 Transport Act 1968 issue before anything else. A column with a formula showing days since last download is five minutes to set up.
EU 561/2006 Article 6 limits: 56 hours maximum driving in a week, and no more than 90 hours of driving in any two consecutive weeks. Your tacho analyser produces that report. A spreadsheet captures it. Fine.
Where it falls apart
The WTD reference period.
The Road Transport Working Time Regulations 2005 — SI 2005/639 — set a maximum average working week of 48 hours, calculated over a rolling 17-week reference period. Not a calendar quarter. Not a fixed window. Rolling. Moving forward one week at a time, continuously.
So when you're looking at the week of 21 September 2026, the 17-week reference period stretching back from that point starts in late May. To check whether a driver is within the 48-hour average, you need 17 consecutive weeks of working-time data — driving hours, other work, availability recorded as work — summed and divided by 17.
A monthly spreadsheet tab doesn't do that. Signed self-cert forms in a lever arch file definitely don't do that.
And there's the 10-hour night work limit. SI 2005/639, Reg 6: if a driver's working time includes at least three hours between midnight and 04:00, the total working time in that 24-hour period can't exceed 10 hours. That's an absolute limit on any day that contains night work — not a rolling average. A spreadsheet can flag this, but only if someone's actively checking night shift hours against that specific rule. In my experience, most TMs doing it manually aren't.
The retention trap I walked into
This is the bit that stung most.
Tachograph data — driver card downloads, vehicle unit downloads — must be kept for a minimum of 12 months under the operator's obligation in EU 561/2006, Article 10. That's what most operators know. What fewer operators know is that WTD working-time records have a separate retention obligation. If the tacho data is the only record of working time you hold — no separate timesheets, no payroll-linked hours records — you need to keep it for 24 months. Not 12. Twenty-four.
I was deleting tacho data after 12 months and calling it compliant. Which it was for 561 purposes. But for WTD record-keeping, with tacho data as my only source, I needed 24 months. When DVSA asked for the rolling 17-week average going back six months, I had the data — just. Another three months into the future and I might not have.
The infringement pattern problem
A tacho analyser report shows individual infringements. Driver missed a break by 14 minutes on Wednesday. Daily rest fell short by 18 minutes on the Friday. Fine. You write it up, you discuss it with the driver, you file it.
What a spreadsheet can't show you easily is the pattern. A driver with two minor daily rest shortfalls in a month is one thing. The same driver with two shortfalls in three consecutive weeks, both on the same route, both at the same time of day — that's a structural scheduling problem. The route is too tight. The delivery windows are causing the breach.
DVSA's infringement analysis looks at patterns. Recurring breaks missed at the same point on a route. Gaps between card removal and next insertion on specific days. The same categories appearing week after week on specific vehicles. On a 12-vehicle fleet running similar routes, that's not something you spot in a spreadsheet unless you're specifically building trend analysis into it — and most TMs aren't.
Fix the schedule and the infringement disappears. Keep reviewing it manually every Monday and the infringement just keeps happening.
The download window — get this right first
If you're still running on spreadsheets and not ready to move, at least get the download timing right. It's what DVSA check first at a roadside stop and it's what escalates fastest.
The clock on the driver card doesn't reset when you download it. It runs from the last data on the card. So a driver who does a download on Monday, then takes two weeks' leave, comes back and drives on the Monday — you now have nine days from the day he drives before his 28-day window expires from when he last drove. Not 28 fresh days from his return.
And that works on the vehicle unit side too. If a truck sits unused for six weeks between the 88-day and 90-day mark on the VU download window, then goes back into service — you need to download it almost immediately. The window was ticking the whole time the truck sat idle.
A mate running five vehicles out of Immingham caught this wrong twice before it clicked. Third time was a roadside stop and a conversation that needed a full download log to resolve.
What the OCRS connection means for small fleets
The reason this matters beyond the fine at the roadside is the Operator Compliance Risk Score. Persistent WTD record-keeping non-compliance found at a premises inspection doesn't just produce an improvement notice. It feeds the OCRS. And once you're in amber, you're getting stopped more at the roadside, which generates more data for the OCRS to feed on.
The TC doesn't need a PG9 to call you to a public inquiry. A pattern of WTD recording failures, a couple of driver infringements, and an improvement notice — that combination is enough. I've seen a 9-vehicle fleet in Coventry end up in a public inquiry with perfectly decent driving hours compliance but WTD records that were in a mess. They kept their licence. But the hearing took six hours and cost them in preparation time they'll never get back.
EU 561 and the WTD are different laws with different clocks. Both matter to DVSA. Both feed the OCRS. A spreadsheet can handle one of them with discipline. It struggles with the other.
If you're tired of manually calculating rolling averages on a Sunday evening, ShiftOwt tracks 561 and WTD compliance automatically — £5.99/mo for drivers, fleet pricing on request.