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A note on Generation 2 tachograph downloading issues

A note on Generation 2 tachograph downloading issues

Wednesday 26th February 2020

• Have you taken delivery of any new vehicles registered after June 15th 2019 fitted with a "generation 2" smart tachograph?
• Do you have more than one company card within the business?
• Have you come across an "invalid card" notification displayed on the tachograph when attempting to download it or had any issues with your downloading devices not picking up data?

If the answer to any of these questions is "yes", please read the following notification:

If you have a fleet of vehicles with more than one operating centre and/or utilize remote downloading of vehicles, it is more than likely that you will legitimately hold multiple company cards. When these cards are issued by the DVLA, they are number sequentially as indicated by the last digits.

Unfortunately, there has been an anomaly in the interpretation of the specification for GEN2 tachographs (Annex 1C), so when multiple company cards are used in the same vehicle it will cause the lower sequenced company cards to become invalid over time. The digit in question is the second digit from the end of the card ID number.

The net effect of this is that if a vehicle is locked in using a card with a higher number, you will be unable to download the tachograph using a card with a lower number, even if it is part of the same batch of company cards.

For instance, you may have a batch of three company cards numbered as follows:


If you use the company card with the number B000000048888031 to initially lock the vehicle in, you will be unable to download the vehicle using the other two cards.

This issue affects both GEN1 and GEN2 company cards.

The background to the problem is as follows:

When Annex 1B (Gen 1 tachograph specification) was first published, the EU Commission put in place EU working groups to discuss and agree implementation processes. The card issuing best practice group identified a problem with the company card numbering system where the specification limits the number of cards that can be issued to a company to 62 cards. In 2003 the 'Best Practice Guidelines' document was agreed across the EU and the solution agreed at the time was the use of the replacement index in conjunction with the consecutive index in order to increase the number of unique character combinations from 62 to 2,232.

Stoneridge have identified an issue with Gen 2 company cards where cards are rejected by the VU if it believes that a replacement card has been issued (insinuating that the 'old' card is now invalid). This is because of the use of the replacement index (15th character) in the card number.

Annex 1B and Annex 1C both have the same wording in respect of the card number, namely that the consecutive index should be incremented where a company has multiple cards. It also states that card numbers should uniquely identify tachograph cards. The issue in Annex 1B has been carried over into Annex 1C.

If you are affected by this problem, the DVLA can issue new company cards that will work around the problem. To assist with this issue, we have created a template email for you to forward to the DVLA to request the replacement cards.

Email to:

Where the note below refers to "XX" can you please fill in the total.

Dear Sir or Madam,

I have been made aware that this email address is to be used to register the fact that our company has vehicles with GEN 2 tachographs and that we have a problem with downloading these vehicles using existing company cards. We have a fleet of XX vehicles with multiple company cards (a total XX) as we have a number of operating centres.

This problem may cause the business to be non-compliant for vehicle downloads without us knowing it has happened. Could you please include us in any further communication on any proposed solution.

If you need any further assistance on this issue, please feel free to contact us on 0330 333 8789.