There has been some discussion in the industry trade press recently that has highlighted proposed changes to how the disease of diabetes is monitored in professional drivers by the DVLA.  One article in Routeone Magazine stated that the DVLA was looking to make the use of new “Continuous Glucose Monitoring Systems” acceptable for professional drivers.  Continuous Glucose Monitoring Systems are considered less invasive than the traditional ‘finger prick’ tests, which also have the disadvantage of needing to be done every 2 hours to ensure correct monitoring of blood sugar levels, which can be disruptive for a driver’s day to day duties.

Continuous Glucose Monitors work by tracking glucose levels throughout the day and night by measuring glucose in the fluid under the skin (what is known as ‘interstitial fluid’). A tiny sensor inserted just under the skin, sends glucose readings to a transmitter, which then in turn sends the data to a receiver (usually a smartphone or a dedicated device). This allows users to see their glucose levels in real-time and track trends, often with optional alarms for high or low levels.

Continuous Glucose Monitors are currently only allowed for holders of ‘Group 1’ licences, but the DVLA is now looking at recommendations from the Confederation of Passenger Transport UK about how to more effectively manage diabetes in the world of vocational driving and how they may implement the relevant changes to the legislation.  The proposed changes could bring significant benefits for many drivers, as roughly 7% of the UK adult population has been diagnosed with type 2 diabetes.

What are the Current Rules on Health Checks for Drivers?

The current guidance issued by the DVLA regarding drivers’ ‘fitness to drive’ states that specific health checks are important for ensuring the safety of both drivers and the general public, and different forms of driving licence have different restrictions relating to the fitness and wellbeing of the licence holder.

The GB medical standards for driver licensing refer to “group 1” and “group 2” licence holders, which differs from the format used on the actual driving licence which has a letter based system to delineate what type and size of vehicle one is licenced to drive on the UK’s roads.

• Group 1 includes all cars and motorcycles which are shown as categories A and B on the driving licence documents.
• Group 2 includes large lorries (over 7.5 tonnes) and buses (coaches), which are shown as categories C and D on the driving licence documents.

Professional drivers for the most part fall into the ‘group 2’ classification.  Understandably, due to the type and size of the vehicles used for haulage and transport of passengers there is a greater responsibility expected of the drivers of that type of vehicle when it comes to road safety and that is reflected in the medical standards that they must pass in order to continue to drive a ‘group 2’ vehicle.

The minimum age for holding a group 2 licence, i.e. a category C or D driving licence is 21 and 24 years old, respectively, unless the driver gains a Certificate of Professional Competency (CPC) at the age of 21, which is possible and would allow them to drive vehicles in the ‘D’ category from an earlier age.  Unlike group 1 licences, which are generally held by members of the general public, group 2 licences must be renewed every five years, or at the age of 45, whichever is earlier for the given period.  From the age of 45 – 65 a group 2 licence must be renewed annually.

Moreover, there are certain restrictions placed on those drivers who suffer from health conditions that are legally known as “sudden disabling events”.  This refers to conditions that could cause sudden seizures, loss of consciousness or fainting episodes, which could cause ‘sudden and unpredictable loss of control and vehicle safety’.  For Group 2 licensing a driver cannot have a greater than 2% likelihood of a sudden disabling event within any one year.

The DVLA is clear that applicants for group 2 licences and holders of group 2 licences have a legal duty to notify the DVLA of any injury or illness that would have any impact on their ability to drive safely, unless these are short term conditions unlikely to last more than 3 months.  The DVLA is also clear that professional drivers have a legal duty to respond fully and accurately to any requests for information from either the DVLA or any healthcare professional regarding their health and ability to drive safely.  This is designed to ensure that there is an adequate level of transparency between drivers and the DVLA and so that any potential medical problems are disclosed at an early stage to ensure road safety.

Doctors, it is interesting to note, are under an obligation to notify the DVLA directly when a patient of theirs who is a driver is considered to be unfit to drive, but where the individual in question is either unable or unwilling to notify the DVLA themselves.  The General Medical Council (GMC) and the General Optical Council (GOC) have made it clear in their guidance to medical professionals that this obligation, whilst a challenge to the patient’s confidentiality, overrides that obligation to their patient and that they must notify the DVLA if they have any concern that their patient could be a liability for road and by extension, public safety if they were to continue to drive.

Licence Revoked?

In order to be able to revoke a licence the DVLA has to collate all relevant medical information on the driver in question and consider the potential risk profile of any health condition that they have been notified of.  In general the DVLA follows a two step process.

1. Information is sought on the condition the driver/medical professional has notified them of.
2. Consultation with the driver’s healthcare professionals is then undertaken to fully gauge the severity of the condition. In some cases this may involve an independent review by a DVLA appointed doctor or the need to undertake a separate driving assessment.

Crucially for drivers, the DVLA is clear about the rules surrounding driving during any medical enquiries.  Sometimes the time taken to obtain all the necessary reports and medical information can be lengthy.  In these circumstances licence holders may be able to retain their entitlement to drive under Section 88 of the Road Traffic Act 1988 but this is always an issue that should be checked carefully and legal advice obtained if there is any doubt.  This obviously has implications for road safety, as drivers may be ‘legally’ allowed to continue to drive with a condition that ultimately will mean that their licence will be revoked once the ‘admin’ is completed. This may have insurance implications for any transport operation that is made aware of the health condition of one of their drivers that currently is under review but which still allows the driver to continue their driving duties.  Whilst the DVLA’s view on this is that it is ultimately the driver’s responsibility (no matter what level of entitlement your driving licence gives one) to assure themselves that they are still fit to drive, whilst awaiting the medical clarification and subsequent licensing decision, as an employer of a member of staff who is undergoing this process one would be well advised to review the duties asked of that member of staff until the situation is decided and seek specialist legal advice before permitting them to continue to drive.

As an Employer, How Do We Know There is a Health Issue with our Drivers?

This is an area where correctly drafted policies and procedures for any member of staff who is qualified to drive large vehicles is key.  Employers have an obligation under Health & Safety law to ensure that all their employees are kept safe at work.  They also have a potential public liability exposure to consider and obligations to their insurance providers to ensure that the drivers of their vehicles are fit to do so.

Once you as an employer have been made aware of a health issue that could impact the employee in question’s ability to drive safely then it may be necessary (or if not necessary, then sensible) to offer that employee other duties within the business whilst the various tests and reviews by the DVLA and healthcare professionals are conducted.

All drivers of large vehicles have a professional duty to ensure that their health is still adequate to allow them to complete their duties safely and ensure that vehicles on the UK’s roads are operated safely and within the regulations.  Health checks are key to ensuring that the UK’s roads are safe for all users and that drivers do not endanger themselves or others.

If you would like any further advice on this issue then please call us on 01279 818280 or click here to send us an email.  We are here to help.

© Richard Pelly, September 2025