Table of Contents
Company locking, why and impact
๐ 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:
โข ๐ Other companies cannot download data โข ๐ Driving and driver data are only accessible with the same company card โข ๐ก๏ธ The data is legally protected (GDPR / social inspection)
๐ชช How does locking work?
1. Insert the company card into the tachograph 2. Select โCompany โ Lockโ in the menu 3. The tachograph: โข registers the company card number โข applies a lock flag to all data from that moment onwards
โฑ๏ธ This only takes a few seconds.
๐ Unlocking
Unlocking is only possible using the same company card that applied the lock.
โข Required in case of: โข vehicle sale โข leasing change โข change of transport company โข Menu: Company โ Unlock
โ Without this card, the data cannot be released.
๐ What happens to existing data?
โข โ Data recorded before the lock remains the property of the previous company โข โ Data recorded after the lock can only be read by the locked company โข The tachograph can therefore contain multiple company locks in its history
โ ๏ธ Important points of attention
โข A vehicle must be locked when it is put into service โข Forgetting to lock = risk during an inspection โข During a check, this may lead to: โข discussions about data ownership โข possible fines
๐ ๏ธ Relation with download devices (such as digiDL)
โข Download tools respect company locking โข Without the correct company card: โข โ no mass memory download โข โ no remote download โข In case of issues, it may appear to be a โcommunicationโ problem, while in reality it is a locking issue
โ Summary
โข Locking = data protection โข Only possible with a company card โข Can only be removed using the same card โข Essential for compliance and audits
Legal obligation
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.
โ๏ธ Is company locking legally mandatory?
โ 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:
๐ Relevant EU legislation
๐น Regulation (EU) No 165/2014 (= basic regulation on the digital tachograph)
This regulation states that: โข the transport undertaking is responsible for the correct functioning and correct use of the tachograph โข the undertaking must be able to protect and manage the data โข only authorised persons may have access to the data
๐ Company locking is the technical means to enforce these obligations.
๐น Regulation (EC) No 561/2006 (= driving and rest times)
โข The undertaking must correctly store, manage and be able to present the data โข Without locking, data can be mixed with data from other companies โ non-compliant
๐งพ What does the inspection expect in practice?
During an inspection (social inspection, ILT, SPF Mobility, police, etc.):
โข The following is checked: โข whether the vehicle is locked to the correct company card โข whether the data is consistent and traceable โข An unlocked tachograph is considered: โข negligent data management โข a risk of data leakage or data manipulation
โก๏ธ This may result in: โข a warning โข an administrative fine โข in some countries: an official report (prosecution)
โ Important nuance
Nowhere does it explicitly state:
โIt is mandatory to lock the tachograph.โ
However:
The undertaking must protect and manage its data โ locking is the only technical way to do so
For this reason, it is considered mandatory in practice.
๐ When must locking definitely be applied?
โข When a vehicle is put into service โข When changing transport companies โข In case of leasing or sale โข When taking over a vehicle โข After unlocking by the previous company
โ Not locking = inspection risk
๐ Relation with remote download
โข Remote download is legally allowed only if: โข the vehicle is locked โข the correct company card is used โข Without locking: โข remote download may fail โข or the data may become legally disputable
โ Summary
โข โ Company locking is legally necessary โข ๐ Based on EU Regulations 165/2014 & 561/2006 โข ๐ The only way to protect data ownership โข ๐ฎ Expected as standard during inspections โข โ ๏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.
๐ง๐ช Belgium
In Belgium, specific fine amounts are defined for tachograph infringements:
โข Non-use or non-installation of the tachograph or driver card: โฌ2,640 (doubled in case of serious infringements) โข 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 โฌ5,280 or more may be imposed, and the total fine can be significantly higher when multiple infringements are combined.
๐ณ๐ฑ The Netherlands
In the Netherlands, fines for tachograph-related infringements can also be substantial, for example:
โข Fines for missing tachograph data can reach approximately โฌ4,400 per vehicle per day in case of serious infringements. โข Other tachograph offences (such as incorrect use of cards) may result in fines ranging from several hundred to several thousand euros.
๐ European variation
In other EU countries, fines vary considerably:
โข Some countries impose fines of โฌ2,000โโฌ4,000 for tachograph-related obligations โข In France, penalties may reach โฌ30,000 and even imprisonment in severe cases โข In Germany, a fine of around โฌ1,500 may apply for certain tachograph-related offences
๐ง Summary
โข Fines related to tachograph locking or compliance are not harmonised across the EU โข In Belgium, failure to correctly apply tachograph obligations can quickly lead to fines of โฌ2,640 or more, significantly higher in cases of fraud โข In the Netherlands, fines for serious tachograph infringements may reach โฌ4,400 per vehicle per day โข 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
โข 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. โข In this case, you will only be able to read technical data, not activities. โข When using our automatic download devices, you will receive an email stating:
โThe file of vehicle XXXXXX contains no activities due to incorrect company locking.โ
