Posted By RP The first thing to identify is if you have an exemption from the Regulations. If you are but are covered by an Operators Licence, it may be a good thing to opt into the scheme anyway as good practice. Other areas to explore if you are exempt is if your drivers also do the odd hobble driving LGV's carrying goods. Extract From DSA: Drivers of the following vehicles will not be required to hold a Driver CPC: i. a vehicle with a maximum authorised speed not exceeding 45 km/h; ii. a vehicle used by, or under the control of, the armed forces, a police force, a fire and rescue authority; iii. a vehicle undergoing road tests for technical development, repair or maintenance purposes, or of new or rebuilt Vehicles which have not yet been put into service; iv. a vehicle used in a state of emergency or assigned to a rescue mission; v. a vehicle used in the course of driving lessons for the purpose of enabling that person to obtain a driving licence or a CPC; vi. a vehicle used for non-commercial carriage of passengers or goods for personal use; vii. a vehicle carrying material or equipment to be used by that person in the course of his or her work, provided that driving that vehicle is not that person’s principal activity. An example of a driver under exemption vii (also known as “incidental driver”) would be a brick layer who drives a load of bricks from the builder’s yard to the building site and then spends their working day laying bricks. In this case, driving a lorry is incidental to their main occupation. However, drivers can move in and out of an exemption, depending on the circumstances in which they are driving. For example, a bus mechanic would be exempt while driving a bus to check that it had been repaired, but would need to hold a Driver CPC if they also drove a bus on a passenger carrying service. We fall into the later part as incidental drivers but have opted to do it anyway as part of the O-Licence agreement to demonstrate training, etc...