EU Directive 2025/2205: what fleet HR teams must do before 2028

A new EU driving licence regime is now in force. Directive (EU) 2025/2205 was signed on 22 October 2025, published in the Official Journal on 5 November 2025 and entered into force on 25 November 2025. It replaces the 20-year-old Directive 2006/126/EC and rewrites the rules on minimum ages, accompanied driving, digital licences, medical fitness and third-country licence recognition. Member states must transpose it by 26 November 2028 and apply it by 26 November 2029.

For HR managers and operations directors, the headline is blunt: the EU has formally lowered the truck-driving age to 18 with a CPC and the bus-driving age to 21 with a CPC across the whole single market, and is opening a controlled door to 17-year-old accompanied lorry drivers. This is the EU's main legislative answer to a sector that, on IRU's latest count, is 444,000 truck drivers short — 12.1% of all positions — and heading for a projected 745,000 shortfall by 2028. Whether that solves anything is the harder question. The rest of this article is what the directive actually says, what it changes operationally, and where it is likely to fall short.

What the directive actually does

Directive 2025/2205 is the operative half of the 2023 Road Safety Package. It is paired with Directive (EU) 2025/2206 on cross-border recognition of driving disqualifications, which amends 2205 to make serious offences — speeding 50 km/h over the limit, drink/drug driving, causing death or serious injury — enforceable across borders. Both repeal the 2006 framework with effect from 26 November 2029 and amend the CPC Directive 2022/2561.

The core minimum ages sit in Article 7. Category C and CE are confirmed at age 18 with a valid Driver CPC; D and DE at age 21 with CPC. Member states retain flexibility to lower D1/D1E to 18 and D to 20 with CPC, but the 50-km limit on under-21 bus drivers remains — a point IRU publicly regretted. The directive also drops the staged-access requirement that previously forced drivers to pass C before CE.

Article 17 is the new accompanied-driving regime. Category B accompanied driving from age 17 is mandatory across the EU - the optional extension to C, C1 and C1E from 17 with CPC is a member-state choice, with mutual recognition between participating states only if they opt in. The accompanying person must be at least 24, hold the relevant licence for more than five years, and — for accompanying a truck candidate — complete 7–14 hours of training or hold the relevant CPC.

Article 18 introduces a mandatory minimum two-year probationary period for all novice drivers, with member states required to apply stricter alcohol rules and sanctions. The text does not impose EU-wide zero-tolerance, but Recital 54 explicitly encourages it.

Digital licences arrive — but not immediately

Article 5 makes the mobile driving licence (mDL) an EU credential issued through the European Digital Identity Wallet under eIDAS Regulation 910/2014, built to the ISO/IEC 18013-5 standard. The Commission must adopt the implementing act on mDL specifications by 26 November 2026, and the mDL becomes the default issuance format 54 months after that act — so realistically around mid-2031. A physical licence remains available on request indefinitely and must be issued within three weeks.

For fleet HR, this is not a 2026 problem but a 2027–2030 systems problem. Verifying an mDL requires registration as an eIDAS Relying Party in each member state of operation, plus integration of ISO 18013-5 verification into driver-management software. Selective disclosure means a transport manager can request only "valid Cat CE?" rather than full personal data — a compliance gain. National wallets are arriving unevenly: Germany, France, Austria, Italy and Poland are on track for end-2026; the Netherlands and Denmark have publicly conceded they will miss the eIDAS deadline. The directive's binding floor is November 2029.

One crucial caveat: the Driver Qualification Card (Code 95) and the digital tachograph driver card are separate credentials. The mDL does not replace either, and the directive does not yet confirm CPC as a standard mDL attribute.

Validity and medical fitness — the older-driver question

Validity stays largely as before: 15 years for car and motorcycle categories (10 if the licence doubles as a national ID), and 5 years for C, CE, D and DE. The new lever sits in the penultimate subparagraph of Article 10(2): member states may shorten validity for residents aged 65 and over, to apply more frequent medical or refresher checks. This is permissive, not mandatory — the Commission's original push for compulsory tighter renewal at 70+ was dropped after pressure from France and Germany.

Article 11 keeps a full medical examination mandatory for issuance and renewal of all C and D categories, regardless of any other check. For categories A and B, member states may substitute the medical with a self-assessment form or a national fitness-monitoring system. Self-assessment is therefore not available for professional truck or bus licences — the safety concern that ETF and the European Transport Safety Council raised during trilogue was partly defused on this point.

Practical translation: HGV medical frequency for your active workforce is unchanged. What changes is country-level variability above 65. Cross-border operators should build a country-by-country renewal calendar from 2028, modelled loosely on the UK regime (HGV medical every five years from 45, annually from 65).

Third-country drivers: a clearer door, not an open one

Article 15 is the structural change for hiring outside the EU. The Commission can, by implementing act, declare that a third country's licensing framework guarantees a "level of road safety comparable to that of the Union", at which point that country's licences can be exchanged with EU-wide validity — replacing the old Code 70 logic in which exchanged licences were not recognised across borders. Country lists are reviewed every four years and published in the Official Journal.

This matters because around 300,000 professional drivers from third countries already work in the EU — roughly 7.5% of the workforce, per the IRU/Commission STEER2EU study. Poland alone issued more than 162,000 non-EU driver attestations by end-2023, with Ukrainians dominating but rising numbers from Uzbekistan, Kyrgyzstan, Kazakhstan, India and the Philippines. The directive does not, however, deliver mutual recognition of third-country CPCs — and IRU EU Director Raluca Marian flagged this publicly: "Without mutual recognition of their professional driving qualifications, third-country drivers remain unable to be employed by EU operators."

The bigger HR lever here is not 2025/2205 but the Single Permit Directive recast (EU) 2024/1233, which member states must transpose by 21 May 2026. It compresses the combined work-and-residence permit decision to 90 days, allows employer changes inside the EU, and grants up to three months of permitted unemployment (six after two years of residence). Add the EU Talent Pool, agreed in trilogue on 18 November 2025 with drivers and mechanics formally listed as shortage occupations, and the SDM4EU project (Skilled Driver Mobility for Europe — IRU-led, ICMPD-managed, EU co-funded, first pilot Egypt–Romania), and the third-country pipeline starts to look coherent for the first time. None of it overrides national immigration law.

What this means for recruiting and retention

Recruiting 18-year-olds. Only five EU countries currently allow C licences at 18 (Finland, Germany, Ireland, Poland, Spain). From November 2029 every member state must. Expect training budgets of €4,000–€8,000 per recruit in Germany, around €5,300 in France for the truck licence alone, and €9,000 for a German bus/coach licence — roughly four times the minimum monthly wage. Apprenticeship infrastructure is the rate-limiting factor: Germany's three-year Berufskraftfahrer dual-training model with a €660–€1,255 monthly stipend is the working template. Insurance pricing for under-25 HGV drivers will be the second friction point; engage carriers early.

Accompanied 17-year-olds. Germany's BF17 car scheme — the policy template — shows 19% lower crash rates and 18% fewer offences in the first year of solo driving for alumni. There is no large-sample evidence yet for accompanied lorry driving specifically. Expect Germany, Austria, Poland and Spain to opt in early; expect the Nordics to resist.

Older drivers. Around 30% of EU truck drivers are over 55, and 17% of the current workforce will retire by 2029. The directive does not force them out earlier. Where member states tighten 65+ renewals, plan for additional medical-screening slots, not workforce exits.

Digital admin. Treat 2026–2027 as the year to specify mDL-ready HR and fleet systems. Telematics providers — Webfleet, Continental VDO, Descartes — will need to publish ISO 18013-5 verification roadmaps. Until then, physical photocards remain the operational document.

Industry reaction: support up top, opposition from the cab

IRU welcomed the directive on adoption day, calling it "long-awaited clarity and modernisation" while explicitly criticising the surviving 50-km bus-driver limit and the missing third-country CPC recognition. National employer associations — BGL in Germany, CETM in Spain, ANITA and Confartigianato in Italy, FNTR in France — have all publicly supported the reform; Germany's BGL is pushing for fast transposition under the slogan "umsetzen, nicht zerreden" ("implement, don't talk it to death").

The European Transport Workers' Federation (ETF) was sharply opposed, headlining its trilogue reaction "This is no longer a Road Safety Package: Council and EP give Green Light to 17-year-olds to Drive Trucks." ETF's argument is structural: the shortage is driven by pay, hours and conditions, not licence age. Their evidence — including a 2021 survey finding 60% of truck drivers regularly drive while fatigued — is harder to dismiss than the Commission and IRU framing implies. ETSC and the European Cyclists' Federation joined the opposition, citing crash-rate data for HGV drivers aged 18–20.

On implementation, no member state has transposed yet — the legal window only opened in late November 2025. Germany is moving fastest on the digital licence (national rollout targeted by end-2026). France, Italy and Spain are largely substantively aligned through pre-existing national law and have not yet tabled transposition bills. Poland — which held the Council Presidency at the time of trilogue — has a draft licensing law that will need rewriting to fit 2025/2205.

The UK is not transposing and has no obligation to. It already lowered HGV minimum age to 18 (in 2009) and scrapped the staged-access rule in November 2021. UK Driver CPC has diverged since December 2024, splitting into International and National streams with shorter modular courses. The UK is developing its own DVLA digital licence on a roughly parallel timeline. EU-licensed drivers working in the UK will continue to need licence exchange and a UK digital tachograph card.

Does it actually solve anything?

Probably not on its own. The directive is a necessary deregulation of age and licence-format barriers; it is not a labour-market policy. IRU's own data shows truck-driver salaries already sit 30–135% above local cost of living in most markets — the bottleneck is conditions, secure parking (only 3% of EU truck parking is certified secure), and onboarding speed, not pay. The under-25 share of EU truck drivers actually fell by 5.8% from 2023 to 2024 despite five countries already allowing licences at 18.

The directive's value compounds only when combined with the Single Permit recast (May 2026 deadline), the EU Talent Pool (live around 2027), CPC reform (expected 2025–26), and serious national investment in apprenticeships and parking. None of that is automatic, and fragmented national implementation — different opt-ins on accompanied trucking, different 65+ medical rules, different mDL launch dates — is the most likely outcome.

The 2026–2029 to-do list

For HR and operations leadership, the planning horizon is now concrete. Track which member states opt in to 17-year-old accompanied lorry driving and build apprenticeship pipelines around them; budget €4–8k per young recruit and pre-negotiate insurance. Map your Single Permit Directive transposition exposure by May 2026. Specify mDL-ready HR and fleet systems during 2026–2027 tender cycles, with verifier-registration paths in each operating country. Build a country-level medical-renewal calendar covering drivers aged 65+. For UK operations, maintain a separate compliance stack — divergence is now structural, not transitional.

The 2028 deadline is closer than it reads. Companies that treat 2025/2205 as a 2029 problem will be hiring against companies that treated it as a 2026 one.