Who must comply, and the key dates
Mobility Package I is a single legislative bundle — Regulations (EU) 2020/1054 and 2020/1055 and Directive (EU) 2020/1057, all adopted in July 2020 — that reshaped three areas of EU road-transport law: drivers' working conditions, market access (cabotage and establishment) and the posting of drivers. It binds road-transport undertakings operating in the EU. The driving- and rest-time rules apply, as a rule, to hauliers using goods vehicles with a maximum permissible mass above 3.5 tonnes and to passenger vehicles built to carry more than nine people, and they took effect in stages: driving and rest times from 20 August 2020, cabotage from 21 February 2022 and posting from 2 February 2022. Enforcement obligations reach further still: the second-generation smart tachograph became mandatory in newly registered heavy vehicles from 21 August 2023, and from 1 July 2026 the tachograph and driving/rest obligations extend to light commercial vehicles between 2.5 and 3.5 tonnes engaged in international transport or cabotage. If you run only vehicles at or below 3.5 tonnes and perform no international or cabotage work, the driving/rest and tachograph obligations likely do not reach your operation before that 2026 date — though the cabotage-access and posting rules can still apply depending on the movement.
Driving and rest times: what Regulation 2020/1054 added
The baseline limits of Regulation (EC) No 561/2006 are unchanged. Under Article 6 a driver may drive at most 9 hours a day (extendable to 10 hours on no more than two days a week), 56 hours in a week, and 90 hours across any two consecutive weeks; Article 7 requires a break of at least 45 minutes after 4.5 hours of driving. Regulation (EU) 2020/1054 added two obligations that bear directly on scheduling and cost. First, a regular weekly rest of at least 45 hours may no longer be spent in the vehicle: it must be taken in suitable accommodation with adequate sleeping and sanitary facilities, and the Commission states that any accommodation costs outside the vehicle are to be covered by the employer. Second, employers must organise work so that drivers can return to the employer's operational centre or to their place of residence within each period of three or four consecutive weeks. This driver-return obligation was challenged before the Court of Justice and upheld in its October 2024 judgment — it remains in force, and should not be confused with the separate vehicle-return rule addressed below.
Cabotage: three trips, four days, and one rule struck down
Cabotage — national carriage for hire or reward performed within a Member State by a non-resident haulier — remains governed by Article 8 of Regulation (EC) No 1072/2009. After an incoming international delivery, a haulier may carry out up to three cabotage operations, and these must be completed within seven days of the international unloading. Regulation (EU) 2020/1055 added, from 21 February 2022, a four-day 'cooling-off' period: once cabotage in a Member State ends, the same vehicle may not perform further cabotage in that Member State for four days — a measure aimed at preventing a continuous foreign presence in a domestic market. A related establishment rule — the obligation for vehicles to return to an operational centre in the Member State of establishment at least every eight weeks (Article 5(1)(b) of Regulation (EC) No 1071/2009, as inserted by 2020/1055) — was, however, annulled by the Court of Justice on 4 October 2024 and is void with effect from its adoption on 15 July 2020. Compliance owners working from older guidance should note that this eight-week vehicle-return requirement is no longer enforceable, even though the three-trip and four-day cabotage limits, and the driver's own return obligation, still stand.
Posting of drivers: which movements trigger it
Directive (EU) 2020/1057 sets a sector-specific rule for when a driver counts as a posted worker — and is therefore entitled to the host Member State's minimum pay and conditions — applicable since 2 February 2022. The dividing line is the type of operation, not the time spent abroad. Bilateral transport operations (carrying goods, or passengers, between the Member State of establishment and another State) and transit through a Member State without loading or unloading are exempt from the posting rules. Cabotage and cross-trade (non-bilateral) operations, by contrast, are covered: a driver performing them is treated as posted. Where posting applies, the operator must submit a posting declaration for the driver through the EU's dedicated Road Transport Posting Declaration portal, built on the Internal Market Information (IMI) system, at the latest at the start of the posting. Whether a given international movement is posting-exempt therefore likely turns on precisely where each loading and unloading takes place: a genuinely bilateral run may keep its exemption, while a cross-trade or cabotage leg will not.
Enforcement and the smart tachograph
Enforcement rests primarily on the tachograph, supported by transport documents and by roadside and premises checks. Mobility Package I accelerated the roll-out of the second-version smart tachograph (G2V2), which automatically records border crossings and loading/unloading — data that makes cabotage sequences and posting-relevant movements far easier to reconstruct at the roadside. G2V2 is mandatory in vehicles first registered from 21 August 2023. Vehicles used in international transport that carried older devices had to be retrofitted: analogue and digital non-smart tachographs by 31 December 2024, and first-generation smart tachographs by 18 August 2025. Member States were required to equip their enforcement authorities with remote-detection equipment by 18 August 2024, allowing targeted stops based on data transmitted from a passing vehicle. From 1 July 2026 the tachograph and driving/rest obligations extend to light commercial vehicles between 2.5 and 3.5 tonnes on international or cabotage operations, closing much of the gap that lighter vans previously occupied.
What to do
Classify each recurring international route as bilateral, transit, cross-trade or cabotage, and file a posting declaration through the EU Road Transport Posting Declaration (IMI) portal for every driver on a cross-trade or cabotage leg before the trip begins — these are the movements that trigger host-country pay and posting obligations.
Sources
Last verified against the primary sources: 2026-07-10
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