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How national reforms and EU legislation are reshaping commercial driver recruitment across Europe — and what practitioners need to know 

 

The IRU puts the number of unfilled driver vacancies across the EU at approximately 426,000 in 2024, with projections of 745,000 by 2028. Over 75 percent of EU land freight moves by truck, which makes this a systemic supply-chain risk, not merely an HR challenge. An ageing workforce — around 30 percent of drivers are over 55 — and the high cost of commercial licensing deter new entrants. A structural legal paradox deepens the problem: obtaining an EU CPC certificate requires 185 days of legal residence, but a residence permit requires an employment contract, which in turn requires a CPC. Migration and work permit procedures take six months to a year — longer than for most other shortage occupations.

 

The EU Legislative Response: Directive (EU) 2025/2205

The fourth EU Driving Licence Directive, Directive (EU) 2025/2205, signed on 22 October 2025 and in force since 25 November 2025, replaces Directive 2006/126/EC and amends Directive (EU) 2022/2561 on professional driver CPC training. Member states must transpose by 26 November 2028 and apply by 26 November 2029. The directive creates a harmonised EU framework for the recognition of third-country category C and D driving licences, replacing the previous patchwork of bilateral agreements. It also introduces a digital driving licence available via the European Digital Identity Wallet by 2030. One significant gap remains: the European Parliament's TRAN Committee had proposed a parallel framework for recognising third-country CPCs, but the Council did not include this in its negotiating mandate. As the IRU has noted, recognising the licence without recognising the CPC solves only half the problem — a driver whose professional qualification is not recognised still cannot legally drive commercially in the EU.

 

National Responses: Speed and Instrument Vary Widely

Member states are not waiting for 2029. Germany has introduced a three-layer reform: the Vorrangprüfung and language checks are suspended at the immigration stage, shifting verification to the employer; Ukraine and Montenegro are proposed for addition to Annex 11 FeV for licence exchange without retest; and the Erstes Gesetz zur Änderung des BKrFQG opens the accelerated basic qualification examination (§ 2 BKrFQG) to eight additional languages — English, Arabic, Croatian, Polish, Romanian, Russian, Turkish, and Ukrainian - once the accompanying BKrFQV ordinance is adopted.

Spain has moved on a different axis: Fenadismer has developed a structured international recruitment programme for Turkish drivers covering language training, qualification acquisition, and residence formalities, while Spain's bilateral licence recognition system for 33 non-EU countries recorded a 12 percent increase in category C and D exchanges in 2025. Poland and Lithuania function in practice as the primary EU entry points for non-EU drivers, with transport companies experienced in international recruitment and intra-EU posting. At the other end of the spectrum, Denmark — despite a documented 24 percent driver shortage — issued only 15 driver attestations to third-country nationals in ten months of 2024, illustrating how administrative capacity constraints can render reform intent ineffective.

 

The Structural Tension: What Has Not Changed

Across these measures, the qualification requirements for commercial drivers have not been relaxed. Directive 2018/645, implemented in Germany through the BKrFQG, remains in force. What has changed is the administrative pathway and the allocation of verification responsibility. Where employers declare compliance without actually checking, the legal and financial consequences of an accident involving an unqualified driver will fall on operators, insurers, and — through third-party liability — on the injured. For claims handlers, the shift in who verifies creates a new exposure line that existing policy wordings may not adequately address. For legal practitioners advising cross-border operators, the patchwork of national implementation timelines means jurisdiction-by-jurisdiction assessment remains unavoidable until the Directive's 2029 application date.

 

Conclusion

The driver shortage is a European problem that is being addressed through EU legislation and divergent national measures. Directive (EU) 2025/2205 provides the eventual harmonisation framework, but leaves the CPC recognition gap open and gives member states until 2029. In the interim, administrative barriers are coming down faster than legal requirements are changing. For transport operators, practitioners, and insurers, the distinction between what is no longer checked and what is still legally required carries significant weight.

 

Picture: AI genereated