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How to Apply for an Operator Licence Without a Transport Manager

If you’re applying for a standard national or international operator licence, a Transport Manager (TM) is normally required by law. However, in certain situations, you can still apply without one—if you meet specific conditions and follow the correct process.

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When You Can Apply Without a Transport Manager

The Traffic Commissioner allows you to apply for an operator licence without a transport manager if:

  • You are applying for a Restricted Operator Licence

  • You are applying for a Standard Licence and request a temporary “Period of Grace” to get a qualified TM

You cannot permanently operate a Standard Licence without a TM. The “Period of Grace” gives you time to appoint one.

What Is a Period of Grace?

A Period of Grace is a formal allowance granted by the Traffic Commissioner. It gives you up to 6 months to either:

  • Find and appoint a qualified Transport Manager

  • Complete your own TM CPC qualification

It must be requested at the time of application or immediately after a TM leaves your business. You need to explain why you do not have one and how you plan to resolve this within the timeframe.

Steps to Apply Without a Transport Manager

1. Choose the Right Licence

  • Apply for a Restricted Licence if carrying only your own goods

  • Apply for a Standard Licence if carrying goods for hire or reward, and request a Period of Grace

2. Start Your Application Online

Go to: https://www.gov.uk/apply-vehicle-operator-licence
Register for the Vehicle Operator Licensing (VOL) system.

3. Fill in the Application

Provide:

  • Business details

  • Vehicle details

  • Operating centre details

  • Financial standing documents

  • Maintenance arrangements

For Standard Licence: explain that you need a Period of Grace. Give a written statement with:

  • Reason you don’t have a TM

  • Steps you’re taking to appoint or become one

  • Timeline to meet the requirement

4. Publish a Local Newspaper Notice

Advertise your operating centre in a local paper for 7 days. Submit the proof as part of your application.

5. Wait for DVSA and Traffic Commissioner Review

Your application will be assessed. If all details are in order, the Traffic Commissioner may grant a Period of Grace and issue a licence under condition that a TM is appointed by the end of that period.

What Happens If You Don’t Appoint a TM in Time?

If the Period of Grace expires and no TM is appointed, the Traffic Commissioner can:

  • Revoke your licence

  • Suspend operations

  • Call a public inquiry

It’s essential to either complete the CPC yourself or appoint a qualified TM before the deadline.

How Blue Flag Transport Consulting Can Help

Blue Flag can assist you with:

  • Drafting the Period of Grace request

  • Preparing your operator licence application

  • Advising on how to become a qualified TM

  • Sourcing external Transport Managers

  • Ensuring compliance from day one

This helps avoid delays, refusals, or future enforcement action.

Need help applying for an operator licence without a TM?
📞 Contact Blue Flag Transport Consulting to handle it the right way. Stay compliant and on the road with expert support.


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