Deadlines for Downloading Tachograph Data: 28 and 90 Days

The two deadlines that carriers most often miss have nothing to do with driving, but with administration. Driver card data must be downloaded at least once every 28 days, and data from the tachograph in the vehicle at least once every 90 days. It sounds simple while you have three vehicles. With twenty vehicles and drivers who are on the road for weeks at a time, it becomes a task that is easy to miss.

Where the deadlines come from

The obligations arise from the Law on Working Hours of Vehicle Crews in Road Transport and Tachographs ("Official Gazette of the RS", no. 96/2015 and 24/2018) and the accompanying Rulebook on the Use of Tachographs ("Official Gazette of the RS", no. 90/2017 and 59/2021). The law has been amended several times, so before relying on any deadline it is worth checking the current version of the regulation.

In essence, the carrier must be able to show, at any time, records of the driver's working hours and of the vehicle's operation. If data is not downloaded regularly, those records do not exist, and there is nothing to prove that the rules were followed.

Why these are two different sets of data

This is the most common misunderstanding in practice. The driver card and the tachograph memory do not record the same things.

If a driver drives the same vehicle for weeks on end, it might seem that the data overlaps. It does not: the tachograph memory contains events tied only to the vehicle that the card does not record, while the card tracks the driver even when they move to a different vehicle.

The deadline is counted backward, not by the calendar

The 28 day, or 90 day, deadline is counted from the previous download, not from the first of the month. In practice this means that "we download on the first of every month" is not a safe schedule: if one download runs a few days late, the next cycle is already at risk.

That is why, in companies that handle this manually, missed deadlines usually do not happen just once, but repeat in a row, until someone notices the drift.

Data retention and the card

Downloading is only the first step. Downloaded data must be kept and made available to the supervisory authority on request. A special rule also applies to the card itself: the driver is required to keep the card for at least 28 days after it expires and to produce it on request.

Data is kept in its original, unaltered format with a digital signature. A report generated by software is not a substitute for the original file, so keeping the source files is just as important as processing them.

What happens if the deadline is missed

Failing to download data within the prescribed deadlines is an offense. Tachograph related offenses are classified by severity, from minor to extremely serious, and fines differ depending on who is being fined: a legal entity, an entrepreneur, a responsible person within a legal entity, or a driver.

We deliberately do not list the amounts here. The penalty provisions have been amended, so any figure copied from an older text can easily turn out to be wrong. Check the current amounts in the applicable version of the Law on Working Hours of Vehicle Crews in Road Transport and Tachographs, or with your industry association.

What matters more in practice than the amount itself: inspections do not happen when it suits you. If data is missing at the moment of an inspection, downloading it afterward no longer helps.

Why manual downloading breaks down

The manual process means someone has to physically reach the vehicle with a download device, or the driver has to bring the card to the office. At smaller companies this works. Problems start when:

• vehicles are on international routes for weeks and do not return to base;
• drivers rotate on the same vehicle, so no one tracks whose card was downloaded when;
• the person responsible for downloading goes on vacation;
• the fleet grows, but the process stays the same.

Each of these cases pushes the deadline back by a few days. Since the deadline is counted from the previous download, the delays add up.

How remote download solves the problem

Remote download removes the human step from the process. A device in the vehicle is connected to the tachograph and sends data automatically, on a set schedule, while the vehicle is on the road. The driver card is read while it is in the tachograph, so the driver does not have to carry it to the office.

This way the deadline is not tracked manually. The system keeps track of when each vehicle and each card was last downloaded, and warns before the deadline expires. We described how this works in practice on the page Remote Tachograph Data Download.

For companies that do not want to handle storing and processing the downloaded files themselves, there is also the option of leaving it to a service. We wrote about that on the Tachograph Data Hotel page, and an overview of the whole set of tools is on the Tachograph page.

Quick checklist

1. For each vehicle, record the date of the last tachograph memory download.
2. For each driver, record the date of the last card download.
3. Set a reminder at 21 days for cards and 75 days for vehicles, to leave a margin.
4. Check whether the source files are being kept, not just the reports.
5. Arrange a backup for the person responsible for downloads during their absence.
6. If vehicles rarely come back to base, consider remote download.

Frequently asked questions