Giltbyte Helpdesk

Introduction

When employees use their own vehicles for work purposes — also known as operating a grey fleet — employers have a legal duty of care to ensure those vehicles are safe, legal, and appropriate for business use. This responsibility is rooted in health and safety law (e.g., Health and Safety at Work Act 1974) and road traffic regulations — and although not always spelled out in law, failure to carry out appropriate checks could expose the employer to liability in the event of an incident.

Recommended Document Checks for Grey Fleet Vehicles

1. Driving Licence

• What to check:

  • The employee holds a valid, full UK driving licence.

  • There are no disqualifications or significant endorsements (e.g., more than 6 points).

  • Licence is for the appropriate vehicle category.

• Frequency: At least annually, or more often for high-mileage drivers or after a road incident.

2. Motor Insurance

• What to check:

  • Insurance must include “business use” (Class 1 minimum).

  • Policy must be in the driver’s name (or include them).

  • Validity dates are current.

• Frequency: Annually at minimum, preferably at each renewal.

Many employees are unaware that commuting cover alone is insufficient for work-related journeys such as client visits, deliveries, or attending off-site meetings.

3. MOT Certificate (if applicable)

• What to check:

  • Expiry date of current MOT certificate, or First MOT due date for vehicles less than 3 years of age.

  • Certificate , or evidence, matches the vehicle registration and VIN.

• Frequency: Annually, once the vehicle reaches 3 years of age.

You can check this using the UK government’s online MOT checker (https://www.gov.uk/check-vehicle-tax).

4. Road Tax (Vehicle Excise Duty)

• What to check:

  • The vehicle is currently taxed.

• Frequency: Annually or upon renewal.

You can check this using the UK government’s online vehicle checker (https://www.gov.uk/check-vehicle-tax).

5. Vehicle Condition Declaration / Inspection

• What to check:

  • The vehicle is roadworthy, with safe tyres, brakes, lights, windscreen, and general maintenance.

  • The employee declares that the vehicle is serviced regularly in line with manufacturer requirements.

• Frequency:

  • Self-declaration annually.

  • Visual checks by managers or fleet staff (optional) every 6–12 months.

6. Vehicle Insurance & Registration Certificate (V5C) – Optional

• Some employers may ask for:

  • Copy of V5C to verify ownership.

  • Full insurance policy (not just a summary).

• Frequency: On employment or vehicle change.

Frequency Summary Table

Additional Employer Responsibilities

• Maintain records of all checks — a register or log is strongly recommended.

• Policy communication: Ensure employees understand the requirement to have business-use insurance and to maintain roadworthiness.

• Incident response: Have a process in place for employees to report accidents, vehicle changes, or licence issues.

• Periodic audits: Spot checks help reinforce compliance.