The digital driving licence can be an improvement in facilitating the freedom of movement. We also welcome the proposed standard administrative validation of 15 years for driving licences A and B.

We are disappointed about some other elements. Inclusion of simulation to test road hazard awareness gives the opportunity to test certain possible situations, but especially for riders of a motorcycle this is not enough. Some elements, like recognising slippery road surfaces, reacting to unclear road situations, reacting to bad weather, etcetera can only properly be trained and tested in real-live situations. Our fear is that driving instructors will train only to deal with the simulated situations, just as already often happens with the current tests. Also, the addition of a hazard perception test by simulation in the theoretical part of the driving licence tests means that for the practical test the focus will remain on low-speed technical skills instead of more cognitive skills.

Progressive access to the A-licence has been mentioned by us many times. There still is no proof that this has a positive effect on road safety. The EC refers to a French pilot but doesn’t give a link to it and such a pilot is not known by us or our French colleagues. Therefor we cannot consider this to be a valid argument to maintain a system that has little or no additional value to road safety and only provides an extra threshold for novice riders to gain a full A-licence. We have also already explained to the Commission, that the current system does not work as it is supposed to do and in certain countries only very few novice riders go through all the steps. On national statistics of issued driving licences we see a sharp decline of A-licences issued to riders under 25 years old after 2013 when the 3DLD was implemented. Nevertheless, statistics show that this does not lead to less crashes with serious injuries or fatalities.

A B-licence allows drivers to pull a small (<750 kgs total weight) trailer behind an M1 or N1-category vehicle. Passing the test for the A-licence does not mean that a motorcyclist is allowed to pull a trailer behind a motorcycle. Nevertheless, trailers that are attached to a motorcycle do exist and are used. This means that a motorcyclist pulling a (small) trailer is moving in a grey area and must consider a patchwork of national regulations when riding cross-border, as the Commission points out with reference to data that is accumulated by FEMA. This situation was first addressed in the Driving Licence Committee on 30 June 2015 and a discrepancy between Directive 2006/126/EC and the type-approval legislation that is mentioned by the Commission was already noticed then. Despite this and several times that we have reminded the Commission of this issue, nothing has changed, and the Commission is just referring to the type-approval regulation as an argument for not solving this problem.

Several member states provide the opportunity to add a national code (usually 196) on the driving licence which allows the holder to ride a small motorcycle (<125cc or electric equivalent) with a B-licence and some additional requirements (age, experience, training) in the own country. In our view harmonisation and the opportunity to ride small motorcycles with a B licence and additional requirements cross-border is required to provide alternative transport where other modes like public transport or active mobility are not suitable or available.

As usual we are willing to provide more detailed information or answer questions from the Commission.