Smart tachograph 2

Smart Tachograph Version 1

Since 15 June 2019, Smart Tachograph Version 1 units have been installed in newly registered trucks and buses. These tachographs feature the same functionalities as previous generations of the digital tachograph, complemented with additional communication tools, such as GNSS (Global Navigation Satellite System) positioning and transmission of real-time information to enforcement authorities by means of a dedicated short-range communication channel (DSRC)*. They also incorporate enhanced anti-tampering measures over previous tachograph versions. 

Smart Tachograph Version 2

Mobility Package I introduced a new version of the Smart Tachograph (Version 2) which incorporates new functionalities for the purpose of enforcement of the EU legislation on cabotage and posting of drivers, such as the automatic recording of border crossings or the detection of the position of the vehicle when a load/unload operation is being carried out. These tachographs facilitate additional information related to the activity of the driver being transmitted to enforcement authorities through the DSRC. Smart Tachograph Version 2 enhances the anti-tampering resistance over all previous tachographs by means of new features, such as its capacity to authenticate satellite signals.

*A dedicated short-range communication channel (DSRC) is a technology that allows enforcement authorities to read infringement related information from passing vehicles by using remote early detection equipment. It serves only as a pre-filter to select vehicles for a more thorough inspection, allowing compliant drivers to continue their journey uninterrupted, saving time and resources.

Mobility Package I requires Smart Tachograph Version 2 units to be fitted to new vehicles first registered since August 2023 regardless of whether they are used for international or national journeys. However, the tachograph retrofit requirements do not apply to vehicles that are exclusively used for national journeys only (noting however that travel through Northern Ireland constitutes an international journey). 

Yes. Vehicles operating internationally include those travelling to, through or from the United Kingdom and are (unless qualifying for an existing exemption) required to comply with the retrofit requirements from the specified dates.

However, if a vehicle which otherwise is used on a national basis only, is being taken in an unladen state to a workshop in Northern Ireland for repair/maintenance work, and the driver can prove same to an enforcement officer at the roadside, then it does not need to be retrofitted with a version 2 smart tachograph by the specified dates. A reciprocal arrangement will apply in respect of Northern Irish registered vehicles being taken into the Republic for repair/maintenance purposes.

Own account vehicles operating internationally include those travelling to, through or from the United Kingdom (including Northern Ireland) and are required to comply with the retrofit requirements from the specified dates, unless they qualify for an existing exemption.

Vehicle operators can confirm the generation and version of the tachograph fitted to their vehicle(s) in the printout and/or from downloading the technical details of the tachograph, or from the manufacturer label on the tachograph.  

Smart tachographs are typically fitted on vehicles first registered since 15th June 2019. On a technical printout it will say ‘GEN2’ for version 1 units and “GEN2 v2” for version 2 units - as per the example below. 

Intellic (recently acquired by ZF) have developed a Smart Tachograph Version 1 which can be identified by the wording on the front of the tachograph. Our understanding is that they have yet to offer Smart Tachograph Version 2 units for sale. 

 

Only two tachograph manufacturers have so far received type approval for their Smart Tachograph Version 2 units. These are VDO (Continental) and Stoneridge. You can identify a Smart Tachograph Version 2 from these manufacturers in the following way:

VDO

VDO Smart Version 2 (DTCO 4.1) has a small Bluetooth icon on the top right-hand side of the display.

Stoneridge

Stoneridge Smart Version 2 (SE5000) shows Smart 2 above the SE5000 name for aftermarket tachographs. Note however that tachographs manufactured for the vehicle manufacturers (OEM’s) will not contain this marking, so our advice is to consult the vehicle manufacturer or their authorised Irish distributor. 

 

You should contact an Approved Tachograph Workshop.  Please visit www.nsai.ie for a full list of Approved Tachograph Workshops by county who can carry out the retrofit/replacement work.

Rules

Where a vehicle presents to an Approved Tachograph Workshop with a malfunctioning tachograph unit, the required version of the replacement tachograph will depend the version already fitted in the vehicle and whether the vehicle is being used for domestic or international journeys.  A summary is as follows:

• Where the malfunctioning unit is a Smart Tachograph Version1, the replacement must be a Smart Tachograph Version 2.
• Where the malfunctioning unit is an analogue or digital non-smart tachograph and the vehicle is operating internationally, the replacement must be a Smart Tachograph Version 2.
• Where the malfunctioning unit is an analogue or digital non-smart tachograph and the vehicle is operating domestically only, replacements must be with the most recent (third) version of the digital tachograph. 

The cost associated with the purchase and fitting of a Smart Tachograph Version 2 is a commercial matter and will depend on various factors, including the age, make and model of the vehicle concerned. You should engage directly with approved tachograph workshops to find out further information on the likely cost relevant to your specific vehicle(s). 

Smart Tachograph Version 2 units requires the use of the Open Service – Navigation Message Authentication (OSNMA) service to authenticate the GNSS position recorded by the tachograph. OSNMA is not yet operational, and work on its introduction is expected to continue until end June 2024 at the earliest.

To address this delay and not inhibit the introduction of Smart Tachograph Version 2, Commission Implementing Regulation (EU) 2023/980 allows a 'transitional' version of Smart Tachograph Version 2 (i.e. without OSNMA functionality activated) to be fitted to newly registered in-scope vehicles, and this will continue for five months after OSNMA becomes operational.

A 'transitional' Smart Tachograph Version 2 is a Smart Tachograph Version 2 that does not have OSNMA (Open Service Navigation Message Authentication) functionality activated.

A 'full' Smart Tachograph Version 2 does (will) have OSNMA functionality activated. These units are not yet available on the market.

Under applicable EU legislation, there is no distinction between a “transitional” or “full” Smart Tachograph Version 2 other than the OSNMA status (i.e. activated or not activated). Vehicles with a “transitional” Smart Tachograph Version 2 units are not required to be retrofitted with a “full” Smart Tachograph Version 2 unit once OSNMA becomes operational.

It is likely to be the end of June 2024 at the earliest when OSNMA becomes operational, and once it becomes available tachograph and vehicle manufacturers will have five months beyond this date to ensure that all Smart Tachograph Version 2 units placed on the market are OSNMA enabled.

It is important to note that ‘transitional’ Smart Tachograph Version 2 units work without OSNMA functionality activated, and these units are currently being installed in all new in-scope vehicles (including those within scope of the retrofit) under production in accordance with the applicable legislation.

Vehicle owners or operators should be aware of this and not wait until OSNMA becomes operational before having the retrofit work carried out. Otherwise you risk a penalty or fine being imposed if detected using vehicles on international journeys without smart Tachograph Version 2 units fitted beyond the compulsory retrofit dates as follows:

• 31 December 2024 for vehicles equipped with an analogue or digital non-smart tachograph (vehicles typically first registered prior to 14^th June 2019).
• 18 August 2025 for vehicles equipped with a smart tachograph version 1 units (vehicles typically first registered between 15^th June 2019 and 20^th August 2023).
• 1 July 2026 for light commercial vehicles and vans with a gross vehicle weight of more than 2.5 tons.

IMPORTANT NOTE: Where a new in-scope vehicle is fitted with a 'transitional' Smart Tachograph Version 2 unit and remains unregistered for a period exceeding five months after the date when OSNMA becomes operational, it will be mandatory to update the tachograph from a 'transitional' to a 'full' Smart Tachograph Version 2 unit before it is registered to ensure it is OSNMA enabled.

However, vehicles fitted with 'transitional' Smart Tachograph Version 2 units prior to a period exceeding five months after the date when OSNMA becomes operational will not need a further upgrade to ensure they are equipped with 'full’ Smart Tachograph Version 2 units.

Nonetheless, if vehicle owners/operators who wish to have the OSNMA update applied on a voluntary basis, our understanding is that this will be possible via a software update applied at a workshop in the future – for example at a future calibration.

Therefore, our advice to vehicle owners/operators is to proceed with retrofits (where required) ASAP and not risk encountering workshop capacity issues and/or potential penalties/fines for failing to act in advance of the compulsory retrofit dates. 

These vehicles now need to be retrofitted with a Smart Tachograph Version 2.

Background

Due to issues with the supply of Smart Tachograph Version 2 units when initially introduced in August 2023, newly registered in-scope vehicles intended for domestic use only were allowed to be registered up to 30 November 2023 fitted with Smart Tachograph Version 1 units.

Enforcement of the the relevant laws was delayed until 1 February 2024, providing a  two month window for commercial vehicle distributors to make arrangements with affected customers to have Smart Tachograph Version 2 units retrofitted.

You may need to update your current download tools in order to be able to download a Smart Tachograph Version 2 unit and driver card. This update may be a software update or in some cases a new device. You should contact your download tool supplier if you have any questions.

Regulation (EU) 2020/1054, was adopted by the EU in July 2020 amending Regulation (EC) No 561/2006 as regards minimum requirements on maximum daily and weekly driving times, minimum breaks and daily and weekly rest periods and Regulation (EU) No 165/2014 as regards positioning by means of tachographs.

Article 3(4) and (4a) of Regulation (EU) No 165/2014 as amended by Regulation (EU) 2020/1054 sets out the legal basis for the implementation dates for the Smart Tachograph Version 2.

These EU Regulations were given full effect in Irish law by the European Union (Road Transport) (Working Conditions and Road Safety) Regulations 2017 (S.I. No. 229 of 2017) as amended by the European Union (Road Transport) (Working Conditions and Road Safety) (Amendment) Regulations 2023 (S.I. No. 567 of 2023).

RSA Transport Officers, Customs Officers and members of An Garda Síochána enforce the provisions of S.I. No. 229 of 2017Open in new browser tab as amended.

Anyone who drives a vehicle fitted with the incorrect version of tachograph is liable on summary conviction to a €5,000 fine (class A) and/or imprisonment for a term not exceeding 6 months. The transport undertaking is also liable to be proceeded against as per Regulation 44(1)c of these Regulations.

In addition, RSA Transport Officers are empowered to require a driver or operator to take a vehicle (or arrange for it to be taken) to a workshop for the tachograph to be inspected and checked for compliance with the regulations.

Learn more about RSA enforcement inspections

Please visit the European Commission website which offers further information on version 2 smart tachographs.

VDO information

• DTCO 4.1 
• DTCO 4.0(E) 

Stoneridge information

• SE5000 Smart 2 

A driver can't take a regular weekly rest or any weekly rest period longer than 45 hours in the vehicle. Accommodation with adequate sleeping and sanitary facilities must be provided at the cost of the employer. 

Regulation (EC) No 561/2006 clarifies and confirms a recent decision of the European Court of Justice regarding taking regular weekly rest in the cab of a vehicle. 

Drivers engaged in international transport now have the possibility to take two reduced weekly rest periods in a row in every 4-week period, provided that the driver in any four consecutive weeks takes at least four weekly rest periods, of which at least two shall be regular weekly rest periods.

The driver must start the reduced rest outside of the Member State of establishment to qualify for this possibility. If the first reduced rest begins inside the drivers’ place of residence, the standard rules will apply.

After two consecutive reduced weekly rest periods, the compensation for both reductions must be taken en bloc before the next weekly rest period. This means that the compensation for both reduced weekly rests must have been completed before the end of 6 x 24 hour periods after the second reduced weekly rest finished.

Employers must organise the work in such a way that drivers can return, within each period of either three or four consecutive weeks (depending on whether the driver had two consecutive reduced weekly rests), to one of the following two places to take their regular weekly rest:

1. Employer’s operational centre in the EU Member State of establishment where the driver is normally based; or
2. Drivers place of residence when it differs from the employer’s place of establishment. 

Unless vehicles are equipped with Smart Tachograph Version 2 units and drivers are using Generation 2 Version 2 driver cards (issued by the RSA since 11 Aug 2023), then drivers must stop at the nearest possible stopping place at or after the border - taking into account road safety rules and avoiding risks of creating dangerous congestion - and manually record the symbol of the country being entered.

The European Commission has prepared Questions and Answers on the manual recording of border crossings in tachographs under Regulation (EU) No 165/2014.

Drivers are required to record the symbol of the countries in which the daily working period starts and finishes.  Note that drivers who leave their card in the tachograph overnight they will not be prompted in this regard and will have to use the tachograph menu to enter the country symbol of start and end working periods.

As per previous regulations, where a driver accompanied a vehicle which was transported by ferry or train and took a regular daily rest period, that period may have been interrupted twice by other activities not exceeding 1 hour in total (access to bunk or couchette is a pre-requisite).

The new rules now allow the interruption to also be applicable to reduced weekly rest periods, under the same conditions:

• Rest period may only be interrupted twice.
• The interruption cannot exceed one hour in total.
• The driver must have access to a, bunk or couchette, or, with the amendment, a sleeper cabin.

A regular weekly rest may now also be interrupted only where the ferry or train journey is scheduled for more than 8 hours, and the driver has access to a sleeper cabin.

Under the new rules, it is possible to exceed daily and weekly driving time by one hour in exceptional circumstances to reach the operational centre or the driver’s place of residence, provided road safety is not jeopardised.

If the driver takes a 30-minute uninterrupted break immediately before this extra driving time, daily and weekly driving time can be exceeded by 2 hours.

It must be compensated en bloc with any rest period by the end of the third week following the week in question.

Since February 2022, there is a  four day cooling-off period after three permitted operations in seven days, during which the operator can't perform cabotage again in the same EU country with the same vehicle.

As per previous rules, a haulier could carry out three cabotage operations in seven days in a country other than its country of registration following an international transport operation.

From 31 December 2024, the period for which drivers must be able to produce record sheets, manual records and printouts is extended from 28 days to 56 days.