Better Fleet: Why grey fleet compliance remains a hidden risk

March 9, 2026

Grey fleet is often treated as a minor administrative issue. In practice, it can be one of the least visible risks in an organisation’s transport activity.

When employees use their own cars for work journeys, employers still carry legal responsibility for ensuring those journeys are safe and compliant. The same duty of care that applies to company vehicles also applies to privately owned vehicles used for business travel.

The challenge is visibility. Company cars and vans usually sit within a structured fleet management system. Personal vehicles do not. As a result, organisations may have detailed oversight of their leased fleet but far less clarity about employees using their own cars for meetings, site visits or travel between offices.

Research suggests those checks are often inconsistent. TyreSafe reports that only around one in three organisations carries out regular checks on core requirements such as MOT, tax and insurance. Separate research from TTC Group found that 18% of organisations never verify these essentials, while many others only review them when a driver first joins the business.

That leaves a wide compliance gap.

The risks go beyond paperwork. Under UK health and safety law, employers must take reasonable steps to protect employees and other road users when work-related driving takes place. If an incident occurs and proper controls are missing, organisations can face investigation, civil liability and reputational damage.

Grey fleet drivers also tend to fall outside the structured support given to company car drivers.

IAM RoadSmart Director of Policy and Standards Nicholas Lyes explains:

“Given that grey fleets are privately owned, organisations often have little oversight on the condition of both the vehicle and the driver. Despite having a duty of care, drivers of grey fleets are more likely to work infrequent hours and have less access to regular and structured training or telematics monitoring.”

Hybrid working has expanded this challenge. Many employees now drive occasionally for work rather than daily. Because driving is not their primary role, those journeys are often overlooked in risk assessments.

The result is what many fleet professionals now describe as the “invisible fleet” – vehicles being used for business activity that sit outside normal fleet oversight.

Leo Taylor, Director of DriveTech, explains:

“With company vehicles, fleets usually have clear processes in place. Regular servicing, licence checks and maintenance records all sit within existing fleet systems. When employees use their own vehicles for work, that visibility can drop away.”

In the next article we look at how organisations are starting to bring grey fleet activity back under control.

Read guidance in this series:

What works when organisations take grey fleet risk seriously

A practical playbook for managing grey fleet risk

Or join Better Fleet for best-practice planning that's proven through real-world case studies: Better Fleet Campaign