Compliance, Efficiency & AutomationHGV & PSV operators · England & Scotland
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The 2024 Guide to Maintaining Roadworthiness: a review

The much-anticipated November 2024 update to the Guide to Maintaining Roadworthiness has arrived — and it proved something of an anti-climax. Here is what actually changed, and what it means for operators.

By Zed Aziz, Transport Consultant

The much-anticipated November 2024 update to the Guide to Maintaining Roadworthiness (GTMR) has finally arrived, and to be fair, it turned out to be something of an anti-climax. Despite the build-up, the new guide brings no ground-breaking changes — in fact, many areas expected to see significant updates have been scaled back. Below, we break down the key elements and explore what they mean for operators.

What actually changed

  • Greater emphasis on choosing reputable service providers for PMIs
  • Brake test requirement broadly unchanged — at least four laden tests including the MOT
  • A new risk assessment expected whenever a laden brake test is not carried out
  • Inconsistent guidance on the timing of laden roller brake tests (7 vs 14 days)
  • Increased emphasis on Electronic Brake Performance Monitoring Systems (EBPMS) for trailers

The big change: selecting good service providers

The most notable change is the emphasis on operators choosing reputable service providers for their Preventative Maintenance Inspections (PMIs). The guide now expects operators to exercise tighter control over their providers and to use accreditation and MOT pass rates as indicators of quality.

The difficulty is that the market for these maintenance and safety inspection providers remains largely unregulated and unaccountable. Operators are tasked with ensuring providers meet high standards, despite having limited control. In theory, competition should drive improvement; in reality, demand far outstrips supply, so providers have little incentive to raise quality and can simply raise prices instead. The idea that operators can "just switch providers" is impractical when there is nowhere else to go.

The service pack dilemma

For operators tied to specific manufacturer service providers — such as Mercedes, Volvo, and Scania — this expectation adds another layer of complexity. These providers often operate as franchises with varied service quality, and operators bound by service packs have little room to manoeuvre or any effective recourse for complaints. Operators who are not tied to a specific provider face the opposite problem: the best independent outfits are already at full capacity and unable to take on new clients, leaving limited options.

Brake test requirements

One of the most anticipated updates was a requirement for brake tests at each PMI. The result was underwhelming: the guide merely reiterates that at least four laden brake tests should be conducted each year, including the MOT — essentially the same requirement as before. An interesting but impractical addition is the new mandate for a risk assessment every time a laden brake test is not conducted. The guidance is vague on who should perform these assessments, making it feel more like a bureaucratic hoop than a practical safety measure. For more on getting brake testing right, see our guide to the roller brake test.

Inconsistencies in laden roller brake test guidance

A further challenge is the inconsistency over the timing of laden roller brake tests. One section suggests the test should take place within 7 days of a PMI, while another extends this to 14 days. For operators on a six-week PMI cycle, a 14-day window seems excessively long and disrupts planning. Operators need clear, consistent guidelines to manage their maintenance schedules; the current ambiguity only adds to the burden.

Electronic Brake Performance Monitoring Systems (EBPMS)

The new guide also highlights the importance of Electronic Brake Performance Monitoring Systems (EBPMS), particularly for trailers, expecting operators to develop a better understanding and application of these systems. For the majority of operators, however, this will have little immediate impact, as EBPMS is not yet widely applicable across most fleets.

What should be in the next guide

To address the current issues and improve road safety, future updates could usefully include:

  1. Stricter regulation of third-party service providers — a licensing system, clear standards, and a regulatory body to oversee and enforce compliance.
  2. Enhanced protection for operators tied to manufacturer contracts — clear dispute resolution, more transparency, and a "right to choose" provision.
  3. Mandatory regular brake testing — ideally a laden roller brake test with every PMI to keep things simple, alongside a more practical risk assessment process.
  4. Increased focus on training and awareness — mandatory driver training on maintenance and safety checks, and a requirement for technicians to hold IRTE or equivalent qualifications.
  5. Technological and data-driven maintenance — encouraging telematics and predictive maintenance, standardised data formats, and the use of AI to optimise maintenance schedules.

How FTC can help

The 2024 update may be modest, but the underlying obligation to maintain roadworthiness is as serious as ever — and the Traffic Commissioner will judge you on your systems, not the guide's shortcomings. Our consultants help operators build robust PMI regimes, manage service providers, and keep clean records, while our maintenance calendar and workshop support keep your scheduling on track. To review your maintenance compliance, get in touch for a free, no-obligation consultation.

FAQs

Frequently asked questions

What is the Guide to Maintaining Roadworthiness?+
It is the DVSA's reference document setting out how operators of HGVs and PSVs should maintain their vehicles to remain roadworthy and compliant. It is widely regarded as the key reference for transport managers on inspection regimes, record-keeping, and brake testing.
What changed in the 2024 update?+
The main change is a stronger expectation that operators choose reputable service providers for their PMIs, using accreditation and MOT pass rates as quality indicators. Brake test requirements were broadly reiterated rather than tightened, and EBPMS for trailers was given more emphasis.
How many laden brake tests does the guide require?+
The 2024 guide reiterates that at least four laden brake tests should be carried out each year, including the annual MOT test. It also introduces an expectation that a risk assessment is completed whenever a laden brake test is not conducted.
How soon after a PMI should a laden roller brake test be done?+
The 2024 guidance is inconsistent on this point — one section suggests within 7 days of the PMI, while another extends it to 14 days. Many operators find the longer window difficult to reconcile with a tight PMI cycle, so erring towards the shorter period is the safer approach.
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