FRIC Risk Alert: Driving Licence Photocard and LGV expiration
1. Intended Audience
All Member Representatives; risk management, insurance and driver training teams.
2. Summary
One of our most frequently asked questions is regarding driving while the driver’s driving licence renewal application is with the DVLA. Given its complexity, our response has been broken down into three main sections for clarity.
Photocard Expiry of all non LGV drivers
Firstly, photocard expiry for all non LGV drivers. The DVLA requires motorists to renew their photocard licence when it expires. Failing to renew and provide a recent photograph can result in a fine of up to £1,000. The photocard is separate to the driving licence.
It is crucial for drivers to keep their licences updated every 10 years to ensure law enforcement agencies can accurately identify drivers and prevent fraudulent use or impersonation. A new photocard includes the latest security features to protect against fraud and may simplify car rentals both in the UK and abroad. Drivers can conveniently apply for a driving licence online, available 24/7.
Once the DVLA approves the renewal, drivers can check their application status online using your national insurance number, driving licence number, and postcode. Typically, licences are updated online a few days before being returned to the driver.
The FRIC motor insurance policy will provide cover for any driver of non LGV vehicles whose photocard has been submitted to the DVLA for renewal provided the DVLA criteria are met (see View or share your driving licence information - GOV.UK ).
LGV category C Expiry
Next, let's cover the expiry of LGV Category licence including LGV Category C . FRIC motor protection does not insure a driver if the DVLA is processing their “any category including LGV” licence renewal.
FRIC protection only provides cover when this vehicle category licence has been renewed, not while it is being processed. Drivers are not permitted to drive until the licence is returned or there is evidence of successful renewal application completion. Drivers can confirm the status using the "View or share your driving licence information" service on GOV.UK.
Medical Fitness to Drive
Finally, regarding medical fitness to drive, FRIC protection does not permit the use of Section 88 exemption for LGV Category C renewals. Drivers can not continue driving if their current licence has expired and their renewal application is still being processed by the DVLA.
Drivers must meet the medical standards of fitness to drive. If advised not to drive by DVLA, a doctor or healthcare professional, they must follow that advice. If drivers are unsure how their condition affects their driving, they should refer to the "Assessing fitness to drive" guide on GOV.UK.
Drivers must have held a valid driving licence, only being permitted by the Fire Authority to drive vehicles for which they have applied, and their entitlement must not have been suspended or revoked by a traffic commissioner.
In general, a doctor or healthcare professional is best positioned to determine if a driver should drive any vehicles while waiting for their licence.
About the FRIC Motor protection policy
FRIC has arranged a motor protection policy through the Mutual’s supporting motor insurer, which is compliant with UK law and tailored to suit FRA requirements. It covers the business of the Fire Authority (but not other business) and social, domestic, pleasure and commuting where required. The protection has been drafted to cover the usual FRA activities, and some of the more unusual activities such as the national resilience programme.
Please note that as motor insurance is a statutory requirement and FRIC is not a licenced motor insurer, your certificate of insurance policy is provided by the Mutual’s supporting external insurer, with FRIC providing a significant layer of protection in the form of an additional layer of deductible.
Approved Drivers:
The FRIC Motor insurance does not specify who can drive a Member’s vehicle, this is a matter for the FRA. The driver must be approved by the FRA, hold the appropriate licence category for the vehicle they are driving, be appropriately trained and be competent to the FRA’s satisfaction in the use of the vehicle. The driver must have the appropriate medical certificate as required. Drivers do not need to be employees, but the vehicle must be used in direct connection with the FRA’s normal business and permitted uses . There is no lower or upper age limit prescribed in the Motor cover for drivers, subject to the relevant UK legislation regarding driving generally.
Permitted uses: As shown on the motor insurance certificate, the vehicles are protected whilst being used on Fire Authority business and where declared to FRIC for social, domestic, pleasure and commuting purposes. The vehicles are covered anywhere within the UK and temporarily in the EU and other countries signed up to the EU treaty covering insurance requirements. A full list of countries is available on the reverse of the motor certificate. The definition of the Fire Authority Business Use is quite wide, but does not protect third parties borrowing or using the vehicles for their own purposes. It specifically excludes any third party business use, even where driven by your employees.
If Members are unsure whether a particular scenario is covered, please contact info@fric.org.uk to discuss the position with us.
As Managers, Thomas Miller are not permitted to give advice, especially legal advice, to FRIC’s Members, as not qualified to do so.
It is not for FRIC or the Managers to stipulate how individual FRAs decide to respond to this issue. We would expect consideration of a series of risk reduction measures to be implemented, including
- At least annual risk alerts providing information on driver responsibilities when renewing a photocard or vehicle category.
- Process to check the status of employee driving licences.
- Identify and publish local policy in respect of what happens when a photocard or driving licence category expires.
In summary
It is the responsibility of the driver and the FRA as Employer to ensure compliance with the DVLA licence requirements and where permitted, the Section 88 criteria at all times while driving before receiving their physical licence.
Actions Required
|
|
3. Impacted FRIC Guidance
| None |
4. Reference Information and Further Reading
| DVLA guidance View or share your driving licence information - GOV.UK (www.gov.uk)
|
| Members may wish to seek a formal legal opinion on the impact of the conflict in duties of claims and criminal cases. |
| None |
| Please note this information is for members only and should not be shared outside of FRIC and its member FRAs without prior approval from the Mutual Manager. |
Document Audit Information | |
Accountable Group/Body | FRIC Board |
Authorised by | Mutual Manager |
Direct enquiries to | |
Date Implemented | February 2025 |
Review by | Redvers Cunningham; Sophia Reed, Sue Nugent; Nic Warmink, Mark Miles |
Validation & Checking | N/A |
Date issued | March 2025 |
- Date
- 25/02/2025
