Changes in the Operations of Carriers

The updated provisions of Regulation No. 340 are aimed at harmonising Ukrainian transport legislation with the social standards of the European Union. They provide for changes not only to the rules governing the recording of drivers’ working time and rest periods, but also establish new requirements for tachographs, transport documentation, and the organisation of international trips.

Who is affected by the changes

The requirements of the Regulation apply to road carriers and drivers working under employment contracts and civil law contracts, as well as to individual entrepreneurs (IEs) who independently carry out transportation activities, drivers engaged under civil law contracts, and persons performing international passenger transportation by taxi or on-demand transport services. The new provisions apply to the main categories of the road transport industry, including:

-       domestic or international freight transportation by vehicles with a weight exceeding 3.5 tonnes (including a trailer or semi-trailer);

-       domestic or international passenger transportation by vehicles equipped with more than 9 seats, including the driver's seat;

-       international passenger transportation by taxi or on-demand transport services if the vehicle has more than 5 but not more than 9 seats, including the driver's seat.

During the period of martial law and for three months following its termination, the provisions of Regulation No. 340 shall not apply to transportation carried out in territories where hostilities are taking place or have taken place, as well as in temporarily occupied territories, in accordance with the List approved by Order No. 376 of the Ministry for Development dated 28.02.2025. They also do not apply to the transportation of goods intended to meet the needs of the Armed Forces of Ukraine or to the transportation of military personnel by vehicles used under a lease (hire) agreement with a driver. An exception is also made for domestic transportation of goods or passengers for an enterprise’s own needs or at its own expense, provided that the duration of such transportation does not exceed 4.5 hours.

Rules on Drivers’ Working Time and Rest Periods

The new version of Regulation No. 340 has not only clarified the composition of working time but has also established detailed rules for recording rest periods. Accordingly, a driver’s daily working time must not exceed 10 hours within any 24-hour period if it falls within nighttime hours (from 22:00 to 06:00). At the same time, the total driving time may not exceed 56 hours per week. The cumulative driving time over any two consecutive weeks may not exceed 90 hours.

The duration of breaks now depends on the length of the working day: if the working day is from 6 to 9 hours, the break must be at least 30 minutes; if it exceeds 9 hours, the break must be 45 minutes or more. The break may be divided into several periods, but each period must be at least 15 minutes long.

A driver’s daily rest period and reduced weekly rest period may be taken in the vehicle only if the vehicle is equipped with a sleeping berth and is parked, on a ferry, or on a train. As we know, prior to this amendment, drivers would often sleep in their vehicle cabs. A driver’s weekly rest period must be at least 45 hours and must be taken under appropriate conditions outside the vehicle cab, which is entirely justified.

Where a driver is abroad, they may take two consecutive reduced weekly rest periods, but only subject to subsequent compensation. During the following four weeks, the driver must take four weekly rest periods, at least two of which must be regular weekly rest periods.

A carrier engaged in international transport operations must organise its activities in such a way that, after every four consecutive weeks of work, its driver has the opportunity to return either to the employer’s place of business or to the driver’s place of residence in order to take a regular weekly rest period.

Requirements for Tachographs

All vehicles falling within the scope of Regulation No. 340 must be equipped with tachographs. Vehicles first registered in Ukraine after  June 30, 2026, and used for international freight transport must be equipped with G2V2 smart tachographs. Where a tachograph is installed, information on working time, periods of availability, breaks and rest periods must be recorded using the tachograph. If the tachograph is temporarily not functioning, the information must be entered manually on the tachograph chart, on a tachograph printout or in a temporary record sheet. Accordingly, the carrier must ensure:

·      reading data from the tachograph memory at least once every 90 days;

·      reading data from the driver's card at least once every 28 days;

·      retention of data for at least 24 months from the date of the last record;

Information relating to drivers’ working time and rest periods must be retained for 56 days, and undertakings must archive such records for two years.

Documentation of Transport Operations

Please note that from July 26, 2026, all consignors are required to use the updated form of the Consignment Note (TTN), in which all mandatory details must be completed. If any mandatory detail is incomplete, such TTN shall be deemed to be absent. In addition, a separate TTN must be completed for each trip with a final destination address. If cargo intended for several consignees is transported in one vehicle, a separate TTN must be prepared for each consignee. If one shipment contains cargo for a single consignee but delivery is to be made to different addresses (for example, different stores), a separate TTN must also be completed for each consignment to be delivered to a specific address. The TTN is mandatory, as it is the principal document in the approved form accompanying the cargo during transportation and serving as evidence of the performance of the transport contract.

Other accompanying documents may include a waybill, on the basis of which the carrier records fuel and lubricant consumption, a transport order, a certificate of completion, delivery notes, specifications, packing lists, etc.

BOX ITEM: For international transport operations, the following documents must be available:

-       CMR (International Consignment Note) – the principal document confirming the conclusion of a transport contract between the parties and the compliance of the cargo with international requirements

-        Carnet TIR – a document for transport operations; it is available here;

-       Green Card;

-       export declaration accompanying the cargo when crossing the border and submitted to the customs authorities (articles 257-265 of the Customs Code of Ukraine);

-       invoice – a document confirming the value of the cargo intended for international trade;

-       certificates of quality and origin confirming the origin and characteristics of the goods.

Fines and Other Penalties

Carriers should bear in mind that violations of Regulation No. 340 entail financial penalties. Compliance with working time and rest period requirements is monitored by representatives of the State Service of Ukraine for Transport Safety (Ukrtransbezpeka).

During roadside inspections, Ukrtransbezpeka verifies drivers’ compliance with the requirements of the European Agreement concerning the Work of Crews of Vehicles Engaged in International Road Transport. This is particularly relevant for carriers providing international transport services. During inspections, special attention is also paid to compliance with working time and rest period requirements, as these are among the most frequently violated obligations. Furthermore, where a trip involves passenger transport over a distance of 500 km or more, or where organised groups of children are transported by bus outside a populated area over a distance exceeding 250 km, the requirement for two drivers on board the bus must be complied with.

Article 60 of the Law of Ukraine "On Road Transport" establishes administrative and economic sanctions specifically for violations of working time and rest period requirements. The amount of the fine is 20 non-taxable minimum incomes of citizens (UAH 340). However, where one person commits more than one violation, a separate fine is imposed for each violation.

Current legislation also provides for administrative liability for violations of the rules governing the provision of passenger or freight transport services (Article 133-1 of the Code of Ukraine on Administrative Offences). For violations of the Article mentioned above, an administrative fine may be imposed on drivers in the amount of 40 non-taxable minimum incomes of citizens (UAH 680), while for individual entrepreneurs and officials of legal entities the fine amounts to 60 non-taxable minimum incomes of citizens (UAH 1,020).

Liability is also established for incorrect completion of a TTN, but only if it is detected during roadside inspections. Therefore, if an inspection establishes that the consignor used an outdated TTN form, failed to complete mandatory details, or completed them incorrectly, the carrier will be fined. This is because, in such cases, the TTN is deemed to be absent. The fine for the absence of mandatory documents is considerably higher and amounts to UAH 17,000.

Natalia Shcherbak,

Accounting and Tax Consultant