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en:manuals:digicentral:notifications:c_lock_addendum

Company locking, why and impact

๐Ÿ” What is company locking?

Company locking links a digital tachograph to one specific company by means of the company card. Once the tachograph is locked:

โ€ข ๐Ÿ“› Other companies cannot download data โ€ข ๐Ÿ”’ Driving and driver data are only accessible with the same company card โ€ข ๐Ÿ›ก๏ธ The data is legally protected (GDPR / social inspection)

๐Ÿชช How does locking work?

1. Insert the company card into the tachograph 2. Select โ€œCompany โ†’ Lockโ€ in the menu 3. The tachograph: โ€ข registers the company card number โ€ข applies a lock flag to all data from that moment onwards

โฑ๏ธ This only takes a few seconds.

๐Ÿ”“ Unlocking

Unlocking is only possible using the same company card that applied the lock.

โ€ข Required in case of: โ€ข vehicle sale โ€ข leasing change โ€ข change of transport company โ€ข Menu: Company โ†’ Unlock

โ— Without this card, the data cannot be released.

๐Ÿ“‚ What happens to existing data?

โ€ข โŒ Data recorded before the lock remains the property of the previous company โ€ข โœ… Data recorded after the lock can only be read by the locked company โ€ข The tachograph can therefore contain multiple company locks in its history

โš ๏ธ Important points of attention

โ€ข A vehicle must be locked when it is put into service โ€ข Forgetting to lock = risk during an inspection โ€ข During a check, this may lead to: โ€ข discussions about data ownership โ€ข possible fines

๐Ÿ› ๏ธ Relation with download devices (such as digiDL)

โ€ข Download tools respect company locking โ€ข Without the correct company card: โ€ข โŒ no mass memory download โ€ข โŒ no remote download โ€ข In case of issues, it may appear to be a โ€œcommunicationโ€ problem, while in reality it is a locking issue

โœ… Summary

โ€ข Locking = data protection โ€ข Only possible with a company card โ€ข Can only be removed using the same card โ€ข Essential for compliance and audits

A logical follow-up question โ€” below is the legal obligation regarding company locking of the tachograph, explained clearly and correctly according to EU regulations.

โš–๏ธ Is company locking legally mandatory?

โœ… Yes, indirectly but unequivocally

The obligation to apply company locking using a company card arises from European tachograph and social legislation.

The core lies in the following regulations:

๐Ÿ“œ Relevant EU legislation

๐Ÿ”น Regulation (EU) No 165/2014 (= basic regulation on the digital tachograph)

This regulation states that: โ€ข the transport undertaking is responsible for the correct functioning and correct use of the tachograph โ€ข the undertaking must be able to protect and manage the data โ€ข only authorised persons may have access to the data

๐Ÿ‘‰ Company locking is the technical means to enforce these obligations.

๐Ÿ”น Regulation (EC) No 561/2006 (= driving and rest times)

โ€ข The undertaking must correctly store, manage and be able to present the data โ€ข Without locking, data can be mixed with data from other companies โ†’ non-compliant

๐Ÿงพ What does the inspection expect in practice?

During an inspection (social inspection, ILT, SPF Mobility, police, etc.):

โ€ข The following is checked: โ€ข whether the vehicle is locked to the correct company card โ€ข whether the data is consistent and traceable โ€ข An unlocked tachograph is considered: โ€ข negligent data management โ€ข a risk of data leakage or data manipulation

โžก๏ธ This may result in: โ€ข a warning โ€ข an administrative fine โ€ข in some countries: an official report (prosecution)

โ— Important nuance

Nowhere does it explicitly state:

โ€œIt is mandatory to lock the tachograph.โ€

However:

The undertaking must protect and manage its data โžœ locking is the only technical way to do so

For this reason, it is considered mandatory in practice.

๐Ÿš› When must locking definitely be applied?

โ€ข When a vehicle is put into service โ€ข When changing transport companies โ€ข In case of leasing or sale โ€ข When taking over a vehicle โ€ข After unlocking by the previous company

โŒ Not locking = inspection risk

๐Ÿ”— Relation with remote download

โ€ข Remote download is legally allowed only if: โ€ข the vehicle is locked โ€ข the correct company card is used โ€ข Without locking: โ€ข remote download may fail โ€ข or the data may become legally disputable

โœ… Summary

โ€ข โ— Company locking is legally necessary โ€ข ๐Ÿ“œ Based on EU Regulations 165/2014 & 561/2006 โ€ข ๐Ÿ” The only way to protect data ownership โ€ข ๐Ÿ‘ฎ Expected as standard during inspections โ€ข โš ๏ธ Not applying it = compliance risk

Possible fines

The exact fine for failing to comply with tachograph obligations varies per country and per type of infringement โ€” there is no single fixed fine across the EU. However, there are guidelines and examples of amounts applied by enforcement authorities.

๐Ÿ‡ง๐Ÿ‡ช Belgium

In Belgium, specific fine amounts are defined for tachograph infringements:

โ€ข Non-use or non-installation of the tachograph or driver card: โ‚ฌ2,640 (doubled in case of serious infringements) โ€ข Fines for other tachograph infringements vary depending on the severity and nature of the fault, but serious fraudulent infringements can amount to several thousand euros under the revised fine catalogue.

In cases of fraud (e.g. deliberate non-recording or manipulation of data), fines of up to โ‚ฌ5,280 or more may be imposed, and the total fine can be significantly higher when multiple infringements are combined.

๐Ÿ‡ณ๐Ÿ‡ฑ The Netherlands

In the Netherlands, fines for tachograph-related infringements can also be substantial, for example:

โ€ข Fines for missing tachograph data can reach approximately โ‚ฌ4,400 per vehicle per day in case of serious infringements. โ€ข Other tachograph offences (such as incorrect use of cards) may result in fines ranging from several hundred to several thousand euros.

๐Ÿ“ European variation

In other EU countries, fines vary considerably:

โ€ข Some countries impose fines of โ‚ฌ2,000โ€“โ‚ฌ4,000 for tachograph-related obligations โ€ข In France, penalties may reach โ‚ฌ30,000 and even imprisonment in severe cases โ€ข In Germany, a fine of around โ‚ฌ1,500 may apply for certain tachograph-related offences

๐Ÿง  Summary

โ€ข Fines related to tachograph locking or compliance are not harmonised across the EU โ€ข In Belgium, failure to correctly apply tachograph obligations can quickly lead to fines of โ‚ฌ2,640 or more, significantly higher in cases of fraud โ€ข In the Netherlands, fines for serious tachograph infringements may reach โ‚ฌ4,400 per vehicle per day โ€ข In other countries, fines may amount to tens of thousands of euros or lead to additional sanctions (driving bans, vehicle immobilisation)

How to check in Orditool

Main menu > Download > Vehicles tab > first column

โ€ข	When a โ— symbol is displayed, this indicates that the tachograph was downloaded using a different company card than the one registered in the tachograph.
โ€ข	In this case, you will only be able to read technical data, not activities.
โ€ข	When using our automatic download devices, you will receive an email stating:

โ€œThe file of vehicle XXXXXX contains no activities due to incorrect company locking.โ€

en/manuals/digicentral/notifications/c_lock_addendum.txt ยท Last modified: 16/12/2025 10:23 by cesar

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