Most operator licence applications and transport manager nominations are decided on paper. But “on paper” does not mean “unexamined”. When a traffic commissioner has doubts about an application, a variation or a nominated transport manager, there are two ways the process reaches out and touches you: written questions, and being called to a public inquiry. Both are competence and credibility checks, and both reward preparation.
Stage one: the written questions
GOV.UK’s guidance for transport managers is explicit about what the commissioner checks before approving you on a licence: that you are qualified, that you will be working enough hours to manage the fleet, that your knowledge is up to date, and whether you have criminal convictions or penalties for breaking UK or EU transport laws. Applications to add a transport manager usually take around seven weeks, and if the commissioner has questions about eligibility, they write to the operator.
Treat that letter as the exam, not an admin step:
- Answer everything, in order, with evidence. A partial answer reads like evasion even when it is just haste.
- Be precise about hours. There are recommended working hours for transport managers, scaled by fleet size: 2 to 4 hours a week for up to 2 vehicles, rising through 8 to 12 for 6 to 10 vehicles, 20 to 30 for 15 to 29 vehicles, and full time at 30 to 50 vehicles. If you propose fewer hours than the recommendation, the guidance says you will need to explain why, and the commissioner can reject the nomination.
- Disclose convictions fully. The commissioner weighs convictions and penalties across driving licences, drivers’ hours, tachograph rules, roadworthiness, weight and dimension limits, international paperwork, dangerous goods and animal transport. An undisclosed penalty discovered later is far worse than a disclosed one explained well.
Stage two: called to a public inquiry
The traffic commissioners’ hearings guide explains that a public inquiry is a formal tribunal hearing, and that one of its three main types is a hearing to determine a licence application. A commissioner can call an inquiry to clarify information that raises concerns. For existing licences, a commissioner who is considering regulatory action must hold an inquiry if the operator requests one, and likewise for action against a transport manager’s repute or professional competence if the transport manager requests it.
Notice periods matter for preparation:
- at least 21 days for an inquiry about an existing goods operator’s licence or a goods application;
- at least 14 days for a passenger licence or application;
- at least 28 days for an inquiry concerning a transport manager.
The calling letter explains why the inquiry is being held, the legislation it is called under, and the evidence the commissioner will consider. That letter is your syllabus. Everything you prepare should respond to it.
What the commissioner is really testing
Whether it is questions on paper or a hearing in person, the underlying questions are stable:
- Do you know what the licence requires? Undertakings, maintenance systems, drivers’ hours management, financial standing. Statutory Document 3 says a transport manager must have relevant knowledge and skills, hold the qualification, and undertake regular refresher training to keep abreast of industry developments. If your CPC is old, a recent refresher course is concrete evidence of current knowledge.
- Is your role real? The transport manager must be involved in transport decision making with genuine autonomy, including the final say on whether a vehicle goes on the road, and must be in a position to have real impact, for example controlling a budget.
- Can you be believed? Commissioners assess candour. Inconsistencies between your answers and the DVSA evidence or your own documents do more damage than the underlying problem.
Practical preparation
- Rebuild the timeline. For an application inquiry, know your own application cold. For a regulatory inquiry, construct a dated chronology of what happened, who knew, and what was done.
- Bring the documents. Maintenance records, driver hours analysis, contracts, the TM1 details, financial evidence. Commissioners notice when the paperwork arrives organised and unprompted.
- Fix first, then explain. If the inquiry was triggered by failures, arriving with the new maintenance provider signed, the refresher course booked and the drivers’ hours policy rewritten transforms the conversation.
- Practice saying “I don’t know, I’ll check”. Bluffing a commissioner is the single fastest way to lose one. Inquiries are usually held in person like a court or tribunal, sometimes with witnesses heard remotely, and you will be questioned directly.
- Consider representation. You can appear with a solicitor or transport consultant. For regulatory inquiries especially, experienced help pays for itself.
The mindset
The commissioner is not trying to keep you out of the industry; they are deciding whether the public can be protected while you are in it. Walk in with current knowledge, honest answers and evidence of a functioning system, and you are giving them exactly what they need to say yes.
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