CPC Holder Regulations

CPC Holder regulations current in use in the Republic of Ireland, are part of (Regulation (EC) No 1071/2009, & subordinate Republic of Ireland (The State) legislation (Road Transport Act 2011), with regard to the occupations related to the management of either Road Haulage Operator’s Licences, or Road Passenger Transport Operator Licences.

These regulations are managed, by the regulatory authority Department of Transport, Tourism and Sport, or DTTS. Within the DTTS there is a dedicated department known as the Road Transport Operator Licencing (RTOL) unit. This unit deals with all regulatory matters pertaining to Road Transport Operator Licencing The enforcement of the Road Transport Operators Licencing regulations, is the remit of the Road Safety Authority (RSA), & An Garda Síochána

It is important to all those in the transport industry to understand, that the CPC Holder must be a person, & not a non-physical entity, such as a limited company, & have a direct and unfettered link with the Road Transport Operator’s Licence holder, i.e. a contract of employment or contract of services.

The regulations in relation to the status of a CPC Holder employment when nominated on a Road Transport Operator’s Licence. Allow for either the CPC Holder to be employed directly, i.e. PAYE employee, director, company secretary, owner or shareholder. Or Indirectly i.e. a self-employed, (Sub-Contract, Freelance, Outsourced), person

If the CPC Holder is employed directly, then the Transport Manager CPC Holder is considered to be an Internal Transport Manager CPC Holder.

If the CPC Holder is employed indirectly, i.e. Self-Employed, Sub-Contract, Freelanced, or Outsourced then the Transport Manager CPC Holder is considered an External Transport Manager CPC holder.

If you wish to know more about the using external transport management, in relation to your Road Haulage Operator’s Licences compliance requirements, then click the link shown.

Fitness or as it is more commonly known Professional Competence, in relation to the Operator Licencing regime refers to the fact that an induvial has meet the qualifying conditions, normally though examination & achieving the required standard, & therefore can be considered as being professionally competent, or having the required fitness, in the managing of road transport operations. This means that they are a holder of a Certificate of Professional Competence, or more commonly known as a CPC Holder. The Chartered Institute of Logistics and Transport is the awarding body of Certificates of Professional Competence in the Republic of Ireland.

If you would like to know more about the Certificate of Professional Competence then please follow the link to our dedicated Certificate of Professional Competence website.

Good Repute:

The definition of a Conviction in relation to the Road Transport Operator’s Licence regulations. Is that a Conviction imposes a penalty with after a which involves An Garda Síochána prosecution, or a court appearance either in the Republic of Ireland, or outside the State, when relating to the good repute of a nominated Transport Manager / CPC Holder.

Please find below a summary of the current Statutory Instruments used by the RTOL (Road Transport Operator’s Licence) Unit as part of the process for determining a Transport Manager / CPC Holder good repute. The individual convictions which make up the listed Statutory instruments can be seen by clicking the PDF document link next to each of the listed Statutory Instruments.    

Road Transport Act 2011: Section 2 (1) Obligation on operator to notify Minister of certain convictions.

Statutory Instrument No. 89 of 2017 European Union (Occupation of Road Transport Operator) Regulations 2017

Regulation (EC) No: 1071/2009 of the European Parliament & of the Council of 21 October 2009, Article 6

Commission Regulation (EU) 2016/403 of 18 March 2016 supplementing Regulation (EC) No. 1071/2009

Vetting Invitation form

The Vetting Invitation in its simplest definition is a document which confirms the applicant’s identification, & gives the regulatory body permission to carry out, checks to confirm that the applicant is who they say they are, via the use of recognised formal documentation, as listed below.

The applicant must provide at least two forms of identification (Copies are acceptable) as part of the process, to validate the identity of the applicant. One of the documents used for the validation must be or contain photographic evidence in relation to the applicant.

There are only certain types of documents acceptable, each document type is given a certain numbers of points, & the applicant must reach the required number of points for verification to be completed. In this case, the points must total at least 100 points.

The acceptable forms of identification are shown below along with the points valve for each document:

  • Irish Driving Licence or Learner Permit (new credit card format): 80 points
  • Irish Public Services Card: 80 points
  • Passport (from country of citizenship): 70 points
  • Irish Certificate of Naturalisation: 50 points
  • Birth Certificate: 50 points
  • Garda National Immigration Bureau (GNIB) Card: 50 points
  • National Identity Card (for EU/EEA/Swiss citizens): 50 points
  • Irish Driving Licence or Learner Permit (old paper format): 40 points
  • Letter from Employer within last two years confirming name and address: 35 points
  • National Age Card (issued by An Garda Síochána): 25 points

An Garda Síochána Vetting

This process is now carried out by an online procedure known as “eVetting” Once a completed Vetting Invitation Form has been submitted by an induvial related to the Road Transport Operator’s Licence application to RTOL (Road Transport Operator’s Licence) Unit of the DTTS (Department of Transport, Tourism and Sport or DTTS), an e-mail from evetting.donotreply@garda.ie will be sent to his or her e-mail address containing a link to an online Garda Vetting Application Form. The individual must then use the link to access and complete the electronic Garda Vetting Application Form and submit it online. Garda Vetting is used to collect information on all convictions resulting from Garda prosecution.

The Good Repute Declaration Form

This form is used by the regulatory, & enforcement bodies; The information contained within any completed form is then used by the State, in relation to the enforcement of Road Transport Operator’s Licence regulations. In areas of Good Repute, & other regulatory matters, were the information is considered as being required for the enforcement of said mentioned regulations.

  1. Is the for the applicant to declaration, via legal documentation that they are of Good Repute as per Road Transport Operator’s Licence regulations
  2. The collect of information relating to “Infringements” or “Convictions” of either Road Transport Operator’s Licence regulations, or other regulations as considered by the State to affect the Good Repute of a person nomination or who is a nominated as the Transport Manager / CPC Holder on a valid Road Transport Operator’s Licence.

Information on convictions or infringements received by the Department will be held in confidence and for a minimum of five years.

If all parties, in relation to a Road Transport Operator’s Licence application have no notifiable convictions or infringements to declare.  The process of completing a Vetting Invitation Form, A Garda Síochána Vetting, & the completing of the Good Repute Declaration Form must be completed, before an application is considered, or even granted.

Any failure to provide full information regarding good repute is a serious offence, and may lead to the application being refused. Any person who fails to provide full information, or who provides false or misleading information, is liable on prosecution to a maximum fine of up to €500,000 and/or up to 3 years in prison.

What is Considered an Infringement?

The definition of an infringement in relation to the Road Transport Operator’s Licence regulations. Is that an infringement imposes a penalty without a Court appearance, either in the Republic of Ireland or outside the State, when relating to the good repute of a person, or entity

Examples of which are listed below:

  • a prohibition
  • on-the-spot fine
  • fixed penalty
  • penalty points

A Conviction which is the result of regulatory action being taken by an enforcement or regulatory body, other than that which involves an An Garda Síochána prosecution, either in the Republic of Ireland or outside the State, is considered as an infringement, when relating to the good repute of a person, or entity

Examples of convictions / infringements by other such regulatory bodies such as:

  • Revenue Authority
  • Road Safety Authority
  • Labour Courts, e.g. Employment Appeals, & Tribunals

What is Considered a Conviction?

The definition of a Conviction in relation to the Road Transport Operator’s Licence regulations. Is that a Conviction imposes a penalty with after a which involves An Garda Síochána prosecution, or a court appearance either in the Republic of Ireland, or outside the State, when relating to the good repute of a nominated Transport Manager / CPC Holder.

Please find below a summary of the current Statutory Instruments used by the RTOL (Road Transport Operator’s Licence) Unit as part of the process for determining a Transport Manager / CPC Holder good repute. The individual convictions which make up the listed Statutory instruments can be seen by clicking the PDF document link next to each of the listed Statutory Instruments.    

Road Transport Act 2011: Section 2(1) Obligation on operator to notify Minister of certain convictions

Statutory Instrument No. 89 of 2017 European Union (Occupation of Road Transport Operator) Regulations 2017

Regulation (EC) No: 1071/2009 of the European Parliament & of the Council of 21 October 2009, Article 6

Commission Regulation (EU) 2016/403 of 18 March 2016 supplementing Regulation (EC) No. 1071/2009

When a CPC Holder is named on a Road Transport Operator’s Licence as the nominated Transport Manager there are a number of operative conditions. (these operative conditions are part of EU regulations in relation to nominated transport managers). These operative conditions are often called the 4/50 regulations, & apply to weather the Transport Manager CPC Holder is considered an internal, or external Transport Manager CPC Holder

The Transport Manager CPC Holder is a resident in the European Community;

The Transport Manager CPC Holder must be suitably qualified to be named, on the operator licence for which he/she is being nominated for.

The Transport Manager CPC Holder whilst acting as the nominated Transport Manager/CPC Holder shall perform tasks solely for the interests of the Road Transport Operator’s Licence Holder

The Transport Manager CPC Holder shall be the transport manager/CPC holder for a maximum of 4 Road Transport Operator’s Licence Holders, or entities, with a combined maximum total fleet of 50 vehicles, whilst acting as the Transport Manager CPC Holder

The Transport Manager CPC Holder hours of work are those as per the Traffic Commissioners Guidance or as per the undertakings attach to the Road Transport Operator’s Licence holder by the regulatory body.

The Transport Manager CPC Holder, & the Road Transport Operator’s Licence Holder must be able to provide a copy of the contract between them upon request.

Please note: The list shown above is not to be taken as exhaustive one, & that other conditions may be added to it. Also, even if all conditions shown or not shown have been met, it is at the discretion of The RTOL (Road Transport Operator’s Licence) Unit whether or not a person can be nominated as the Transport Manager CPC Holder on any Road Transport Operator’s Licence.

Within the regulations, this guidance setting out conditions on how a nominated Transport Manager CPC Holder, carry out their work. This guidance is considered as obligatory guidance, (The obligatory guidance  is part of EU regulations in relation to nominated transport managers)& is used by The RTOL (Road Transport Operator’s Licence) Unit, when considering of any nomination of a Transport Manager CPC Holder. Please find this obligatory guidance points below.

Any nominated Transport Manager CPC Holder are normally required to be within a reasonable distance of the nominated operating centre as named on the Road Transport Operator’s Licence, that he or she is nominated on. There is no minimum or maximum distance or time of travel stated within the obligatory guidance. The guidance is used against each nomination, on the known facts & on its own merits.

A rule of thumb, in regard to being within the guidance. Is that 1.5, to 2 hours is a maximum travel time, but if a Transport Manager CPC Holder is nominated on more than one Road Transport Operator’s Licence, then the RTOL (Road Transport Operator’s Licence) Unit may feel that any further requests for nomination on additional Road Transport Operator’s Licences. May be subject to the distance & travelling time being reduced & smaller than that of the rule of thumb figure stated. If those nominations are to be granted by the RTOL (Road Transport Operator’s Licence) Unit.

A further part of the obligatory guidance is in relation to the number of hours per week that a nominated Transport Manager CPC Holder, is the requirement to make sure that the Transport Manager CPC Holder has the available time, to maintain the required level of compliance on the Road Transport Operator Licence(s) that they are nominated on. This figure is determined by the number of vehicles that the operator can operate at any given time, also known as the operating authority, and would be shown on the Road Transport Operator’s Licence document, or the Road Transport Operator Licence application document.  

This part of the current obligatory guidance in relation to External Transport Manager CPC Holder hours of work. Please see figures further down this page.

If you looking at using external transport management services, click the link shown (Link to external transport manager / cpc holder page placed here.)

Also, the figures shown below are a good indicator to those, Transport Manager CPC Holders who work under conditions recognised as being an Internal Transport Manager CPC Holder. As to the number of hours they need to carry out the role, in order to maintain compliance to the Road Transport Operator’s Licencing regime.

0 to 2 Vehicles: 2-4 hrs per week

3 to 5 Vehicles: 4-8 hrs per week

6 to 10 Vehicles: 8-12 hrs per week

11 to 14 Vehicles: 12-20 hrs per week

15 to 29 Vehicles: 20-30 hrs per week

30 to 50 30 Vehicles: A Full Time Transport Manager CPC Holder is required, to be employed, this would normally be on an internal basis

Above 50 Vehicles: A Full Time Transport Manager CPC Holder is required and additional administration assistance may be required

Please Note: Even if there are no vehicles place on the operating authority, i.e. the number of vehicles stated on the Road Transport Operator Licence, which Transport Manager CPC Holder is nominated on. It is both the Transport Manager CPC Holder, & the Road Transport Operator Licence Holder. To ensure that the Transport Manager CPC Holder has the available time to maintain the compliance, matching the guidance set against the operating authority of the, Road Transport Operator Licence, or application. That the fore mentioned parties are named on.

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This Website and the information shown on it, has been produced as a basic guide, to show the relationship between a CPC Holder, & the Operator Licence Regime. Therefore, it cannot be considered as formal legal advice.