New obligations for light commercial vehicles: implementation of the EU Mobility Package as of July 2026

1. Introduction

The European Union's Mobility Package I is a set of rules adopted in 2020 with the aim of harmonising road transport conditions, improving road safety, ensuring fair competition between companies and strengthening the protection of drivers in the internal market.

These rules did not create a new system, but amended and extended existing regulations and directives. This meant that rules historically applied to heavy goods vehicles were progressively extended to other types of transport, including light commercial vehicles operating internationally.

Mobility Package I consists mainly of the following legislative acts:

• Regulation (EU) 2020/1054
• Regulation (EU) 2020/1055
• Directive (EU) 2020/1057

Although the Mobility Package was adopted in 2020, the European legislator set transitional periods for the industry to adapt.

For light commercial vehicles (LCVs) with a maximum authorised mass of more than 2.5 tonnes and up to 3.5 tonnes, the effective implementation of many of these rules has been set for 1 July 2026, from which date these vehicles will be subject to a regulatory regime similar to that of heavy goods vehicles when operating internationally.

The obligations listed below apply to EU and non-EU drivers employed by EU transport companies.

2. Driving rules and rest periods

From 1 July 2026, drivers operating LCVs in international transport or cabotage will have to comply with:

• Daily driving limit: maximum 9 hours, extendable to 10 hours only twice a week.
• Weekly limit: maximum 56 hours.
• Two-week limit: maximum 90 hours in total.
• Mandatory breaks: at least 45 min after 4.5 hours of driving (possible division of the break into two fractions, one of 15 minutes after driving 2 hours and one of 30 minutes after driving 2.5 hours).

Breaks:

• Daily: minimum 11 hours without interruption (or 3 hours + 9 hours in two periods without interruption).
• The daily rest period may in some circumstances be reduced to 9 hours uninterrupted.
• Weekly: minimum 45 hours uninterrupted, e.g. from 13:00 on Saturday to 10:00 on Monday. It is possible to reduce this rest period to 24 hours, provided it is subsequently compensated.

These times are in line with the driving and rest time requirements that the EU imposes to improve the safety and welfare of drivers and to bring LCV obligations in line with those of HGVs.

3. Posting rules (posting of drivers)

If a person works for an operator established in one EU Member State and is temporarily posted to another Member State to carry out certain types of transport operations, he/she is considered as a posted driver under EU law.

The type of carriage must be taken into account in order to determine whether a driver is a posted driver and therefore subject to the obligations set out above:

• COBOTAGE: if the person works for an employer who is not established in the Member State where he carries out national transport operations, he is considered to be a posted driver.
• CROSS-TRADE: if he/she carries out transport operations between two Member States, or between a Member State and a country outside the EU, and his/her employer is not established in any of these countries, he/she is considered as a posted driver.
• BILATERAL: if you transport from the Member State where your employer is established to another country (inside or outside the EU), or back from any other country (inside or outside the EU) to the Member State where your employer is established, you are not considered as a posted driver.
• TRANSIT: if he crosses a Member State without loading or unloading, he is not considered as a posted driver.

If a driver is temporarily posted to another Member State by his employer, he will be subject to the rules on pay and working conditions of the country where he provides the services (known as "posting"), and may also involve improvements in his pay and conditions.

4. Compulsory smart tachograph (smart tachograph, version G2V2)

Mandatory on board all LCVs concerned from 1 July 2026 in international or cabotage transport.

It is a digital device that electronically records driving times, rests, stops, borders and other data, with high safety standards.

Absence or misuse can lead to penalties and operational problems (such as immobilisation, fines, etc.).

Link to the recommendations of the European Labour Authority

Information note prepared by the Public and Regulatory Law Department of ECIJA Madrid.