Must a tachograph card be used on regular bus services of up to 50 km?
In short
Under Article 3(a) of Regulation (EC) No 561/2006, regular passenger services where the route does not exceed 50 km are only exempt from the driving and rest time rules — not from the obligation to fit a tachograph: Section 92 (2) of Hungarian KöHÉM Decree 6/1990 (IV. 12.) requires recording equipment for M2/M3 vehicles, and the regular-service bus is not on the list of exemptions in Section 92 (3). Under Article 34 of Regulation (EU) No 165/2014, the driver card must be used in a vehicle fitted with a tachograph.
The analysis below is a professional legal interpretation, not legal advice; it was prepared using professional material produced with the support of Ecomotive School Zrt. — Dénes Petrovai, CEO and head of the driving school. [Consent is required to mention the name and the company]
The legal chain, step by step
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The exemption is narrower than you might think
Under Article 3(a) of Regulation (EC) No 561/2006, the regulation does not apply to vehicles used for regular passenger services where the route covered by the service does not exceed 50 km. This is an exemption from the driving and rest time rules — not a general exemption from every tachograph obligation.
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Rest time ratios must be ensured here too
Section 18/K of the Hungarian Act I of 1988 on Road Transport (Kkt.) requires that the work schedule of the driver of a regular service of up to 50 km be set — on the basis of Regulation (EC) No 561/2006 — so that the driving breaks and the extent and ratio of driving and rest times continuously ensure the driver's fitness to drive safely; Section 18/M sets out the detailed rules on daily rest. So the obligation exists — the only question is the means of proving it.
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The tachograph must be fitted
Under Section 92 (2) of Hungarian KöHÉM Decree 6/1990 (IV. 12.), vehicles of categories M2, M3 and N that fall within the scope of Regulation (EC) No 561/2006 and Regulation (EU) No 165/2014, or of the AETR Agreement, must be fitted with recording equipment; the list of exemptions in Section 92 (3) (public budgetary bodies, agricultural transport within 100 km, own-account buses with a maximum of 17 persons, etc.) does not include the regular-service bus.
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Where there is a tachograph, the card must be used
Under Article 34(1) of Regulation (EU) No 165/2014, drivers must use record sheets or driver cards every day on which they are driving, starting from the moment they take over the vehicle.
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The practical argument
Without card use, a driver could restart their daily driving time with another employer — even on the same day — without any record: exactly the situation the legislator intended to prevent with the driving and rest time rules. Card use is the only objective proof, also accepted by the authorities, that rest time ratios have been observed.
What does FleetControl add?
The number of the inserted driver card is available in a standard format on the vehicle's CAN system — FleetControl uses it for automatic driver identification: the logbook, trip records, driving analysis and every report are linked to the driver, without a separate device or separate administration. In public transport operations, this means that proof of service delivery, the base data for payroll and the rest time documentation are all produced from a single device that is already mandatory — the tachograph.
Frequently asked questions
If the service is under 50 km, does the bus need a tachograph at all?
The obligation to fit M2/M3 vehicles is set by Section 92 (2) of the KöHÉM Decree; the regular-service bus is not among the exemptions in Section 92 (3). And under Article 34 of Regulation (EU) No 165/2014, the card must be used in the installed tachograph.
What is the difference here between the exemption and the obligation?
A regular service of up to 50 km is exempt from the strict driving and rest time limits of Regulation (EC) No 561/2006 — but under Sections 18/K–18/M of the Kkt., rest time ratios must still be ensured and proven.
How does the company benefit from this, rather than just having an obligation?
With card-based driver identification, the obligation becomes a data source: automatic logbook, performance and fuel consumption reports per driver, and an objective basis for payroll.
Legal references
Regulation (EC) No 561/2006, Article 3(a) · Regulation (EU) No 165/2014, Article 34 · Hungarian Act I of 1988 on Road Transport (Kkt.), Sections 18/K and 18/M (njt.jog.gov.hu) · Hungarian KöHÉM Decree 6/1990 (IV. 12.), Sections 92–93 (njt.jog.gov.hu)