Grey fleet checklist

If your staff use their own cars for work journeys, you share responsibility for making those journeys safe and legal. This checklist sets out what to check, why it matters and how often to look again. It's written for businesses and for the HR, office and facilities managers who usually look after it.

Using company cars or vans? See our guide to company vehicle MOT and tax checks.

What grey fleet means

A grey fleet car is one that a member of staff owns and drives for work: a visit to a client, a trip between sites, a run to the bank. Official health and safety guidance is clear that cars used under a car allowance or cash allowance scheme are grey fleet too, even though you pay towards them.

Driving between home and someone's normal place of work is commuting, which official guidance says is not generally classed as driving for work. A journey from home to somewhere that isn't their normal workplace usually is.

What it means for you: if anyone on your team claims mileage or receives a car allowance, you have a grey fleet, whether or not you call it that.

Regardless of how frequently this occurs, it's still an employer's responsibility.

What the law says

Health and safety law applies to work on the road in the same way as it does on a fixed site, and official guidance for employers says plainly: "The law applies to both company and grey fleet vehicles." That means including work driving in your risk assessment, looking at the journey, the driver and the vehicle.

The same guidance says employers should make sure privately owned vehicles used for work are safe, and that workers must check their vehicles, have them serviced and have insurance and a valid MOT.

Road traffic law adds specific duties. Under section 143 of the Road Traffic Act 1988, a car must not be used on a road unless insurance is in force "in relation to the use of the vehicle" by that driver, and it is an offence to "cause or permit" someone else to use a car without it. The rules on licences (section 87) and MOTs (section 47) use the same "cause or permit" wording. These rules apply in England, Wales and Scotland.

What it means for you: if you ask or allow someone to drive for work without the right insurance, licence or MOT, you may be committing an offence as an employer, as well as the driver.

The checklist

Go through these six points for everyone who drives their own car for work: before their first work journey, and then on a regular schedule.

1. Driving licence

Check that the driver holds a full licence for the car they drive and isn't disqualified. The free GOV.UK licence service shows the vehicles they can drive, any penalty points and any disqualifications, using a check code the driver creates. Our guide to checking an employee's driving licence explains each step.

What it means for you: a licence check confirms the right to drive. It says nothing about the insurance or the car, so it's one point on this list, not the whole list.

2. Insurance that covers business use

The law requires insurance for the way a car is being used, not just for the car itself. Policies set out the uses they cover, so a policy without business use can leave a driver uninsured on work journeys. Ask each driver to confirm that their cover includes driving for your business, and to tell you straight away if it changes or lapses.

What it means for you: seeing a certificate once doesn't tell you the cover is still in place months later. Policies renew, change, get cancelled and expire.

Motoble for Fleets lets each driver confirm their cover quickly and easily, through a link, with no app or account to set up, so you don't need to collect and store copies of their insurance documents, with automated reminders so you don't need to keep chasing people.

3. MOT

Most cars need an MOT every year once they're three years old. Using a car on the road without a valid MOT certificate is an offence, and so is causing or permitting it. You can see a car's MOT status and history with the free GOV.UK MOT history service, or even more easily with Motoble's free vehicle check. Motoble for Fleets automates this and other checks on a schedule, helping you stay compliant and keep your operations safe and responsible.

What it means for you: an MOT shows the car's condition on the day of the test. Official guidance points out that an MOT only covers basic defects and doesn't guarantee a car is safe, which is why servicing is on this list too.

4. Vehicle tax

It is an offence to use or keep an untaxed car on a public road. Again, you can check that each car is taxed with the free GOV.UK vehicle tax checker, or as part of Motoble for Fleets' automated, fleet-wide schedules.

5. Servicing and condition

Official guidance asks employers to make sure privately owned cars used for work are safe, and asks workers to check their cars and have them serviced. In practice, ask drivers to:

• have the car serviced in line with the manufacturer's recommendations
• check tyres and wipers regularly, and replace them when needed
• get faults and warning lights looked at promptly
• never use a car for work while it's unsafe

Motoble's MOT history readings can help you spot cars with a pattern of problems, so you know where to ask questions.

What it means for you: you don't need to inspect staff cars yourself. You need a clear rule that unsafe cars aren't used for work, and a simple way for drivers to confirm their car is maintained, without them needing to be trained mechanics.

6. Fitness to drive

Drivers must tell the licensing agency if they develop a medical condition that could affect their ability to drive safely, or if one gets worse. They must also wear glasses or contact lenses every time they drive if they need them to meet the eyesight standard. A licence check won't show a condition that hasn't been reported.

Tiredness matters too: official guidance lists fatigue among the hazards of driving for work, so plan work journeys with enough time and breaks.

What it means for you: ask drivers to tell you about anything that affects their driving, and make it easy for them to raise, for example as part of the driver declaration they sign.

How often to check

No law or official guidance sets a fixed timetable for grey fleet checks. Many employers choose a schedule based on risk:

• check everything before someone first drives for work
• ask drivers to confirm their licence, cover and car at regular intervals, such as every quarter
• check again when something changes: a new car, a new policy, new penalty points, a job change or a new medical condition
• check more often for people who drive a lot of miles for you, drive certain vehicles or work in higher-risk industries
• your insurer may require you to check at a set frequency

Whatever schedule you choose, write it into your driving for work policy, apply it to everyone and keep a record of each check. Your insurer may ask what checks you make.

Motoble for Fleets lets you set how often each driver confirms their licence, cover and car, and keeps a dated record of every declaration, so you can show what was checked and when.

The default schedule for driver declarations is quarterly, but the schedule can be customised by fleet, grouping and/or driver, and additional declarations sent either when things change (e.g. a licence expiry) or when you trigger one.

Mileage claims

If you pay staff for business miles in their own cars, HMRC sets an approved amount you can pay each year without reporting it. A mileage claim is also a useful prompt: anyone claiming for work miles is a grey fleet driver and belongs on your checklist.

Motoble makes free vehicle checks, with MOT history, tax, clean air status and much more.

Questions