Cabotage, own account and occasional trips: when the G2V2 tachograph is really required

Three of the most frequent questions we receive from Italian fleet managers are variants of the same doubt: “do I really need to install the tachograph if I cross the border only once a month?”, “is own account exempt?”, “does occasional cabotage count?”. All three stem from an imprecise reading of the rule. The 1 July 2026 obligation on 2.5–3.5 t vans is more subtle than the summaries you read around, and getting caught in the edge cases can be expensive.

In this article we take the three most frequent scenarios and resolve them with concrete examples, tables and a quick check you can apply to your case. For the general regulatory picture we refer to the operational guide to the tachograph for 2.5–3.5 t vans; if instead you want to find out in 4 questions whether you are required, try our interactive decision tree.

Cabotage: what it is and what it isn’t

Cabotage is the transport of goods carried out within a Member State of the European Union by a haulier established in another Member State. It is regulated by Regulation (EC) 1072/2009 and amended by the Mobility Package with more restrictive rules from 2022.

There are two basic rules. The first dates back to the original 2009 text; the second has applied since 21 February 2022:

• Maximum 3 cabotage operations in the 7 days following an inbound international transport.
• 4-day cooling-off period before performing a new cabotage in the same Member State with the same vehicle.

Cabotage is reserved for holders of a Community licence, which vans over 2.5 t have needed since 21 May 2022. The tachograph requirement followed on 1 July 2026.

What cabotage looks like in practice

Cabotage means: your Italian haulier delivers a load to Germany, then picks up a German load for a German consignee. That second delivery is cabotage. If they add a third internal German delivery, two of the three permitted operations are used up.

What is not cabotage:

• Going to Germany, unloading and returning empty to Italy. This is pure international transport.
• Going to Germany, unloading, picking up a German load destined for an Italian customer and returning. This is a second international transport, not cabotage.
• Operating a regular round-trip service between two countries. This is international transport.

The tachograph implication

The key point: as soon as you make a single cabotage operation with a vehicle >2.5 t MAM, the G2V2 obligation kicks in on that vehicle from 1 July 2026. Even if the trips are rare, even if the vehicle is “mainly domestic”. The rule applies to the vehicle at the moment it performs that operation.

For companies that operate mostly in Italy but occasionally accept return trips with a local load abroad, the decision is sharp: either you give up that type of operation, or the vehicle must be upgraded.

Cabotage in Italy in numbers

In 2024 cabotage in Italy came to 2.9 billion tonne-kilometres, the third-largest volume in the EU after Germany and France, and almost half of it was carried out by Lithuanian (25.6%) and Polish (20.0%) hauliers. In the same year, cabotage by Italian hauliers abroad fell by 27.8% compared with 2023 (Eurostat). International haulage shows the same pattern. Italian hauliers now carry 19.0% of the freight volume Italy imports and exports by road, down from 36.1% in 2004 (Bank of Italy).

For an Italian SME weighing up an occasional job abroad, the numbers point one way. Cabotage has become a specialists’ market, and each operation brings the licence, the tachograph and the posting obligations with it. The cabotage glossary entry sums up the rules in one place.

Own account vs. for-hire: the Mobility Package trap

One of the most widespread beliefs is that own account is exempt from tachograph obligations. Above 3.5 t it never was. For 2.5–3.5 t vans it was true until 30 June 2026, just as it was for hire or reward, and it is still true for national transport. For international transport, however, from 1 July 2026 the exemption is no longer automatic: it depends on who is driving.

What changes from 1 July 2026 for own account

Regulation (EC) 561/2006 has applied since 2007 to every goods vehicle over 3.5 t, on own account as well as for hire or reward, save for targeted exemptions. A tachograph must be fitted and used in every vehicle to which Regulation 561/2006 applies (Article 3 of Regulation (EU) 165/2014). The Mobility Package did not change that scope on 21 May 2022: what it extended to vehicles over 2.5 t on that date was the Community licence, which is required for international transport for hire or reward and from which own-account transport remains exempt.

From 1 July 2026 Regulation 561/2006 also applies to vehicles over 2.5 t used in international transport or cabotage operations (Article 2(1)(aa)). For vans up to 3.5 t, however, the same package provided for an exemption. Article 3(ha) excludes goods transport on the own account of the company or the driver where driving is not the main activity of the person driving the vehicle. In practice, international own-account transport with a van falls under the obligation when the person at the wheel is in fact a driver, and stays outside it when driving is ancillary to another job.

In short:

• National own-account transport with a 2.5–3.5 t van: not required to fit G2V2.
• International own-account transport with a 2.5–3.5 t van: required from 1 July 2026 if driving is the main activity of the person driving, exempt if it is not.
• Own-account transport within another EU State: no limit of 3 operations in 7 days and no cooling-off, which apply to cabotage for hire or reward. For own account, Article 8(6) of Regulation 1072/2009 states that permission to carry out cabotage operations “shall be unrestricted”. The tachograph depends on the international journey that takes the van there, so the rule in the previous point applies.

Real examples

Residual exemptions for own account

The Italian MIT circular prot. no. 9674 of 16 April 2026 applies the exemption in Article 3(ha) of Regulation 561/2006. A 2.5–3.5 t van is exempt if the transport is on own account as defined by Regulation (EC) 1072/2009 (the company’s goods, its own vehicle and staff, transport only ancillary to its business) and if driving is not the main activity of the person driving. It is the typical case of the craftsman using the van to bring their own materials to the construction site, abroad included. The load does not have to be work materials, though, and there is no distance limit: those conditions belong to a different exemption, Article 3(aa), which only applies within 100 km of the company’s base.

The exemption exists, but it is interpreted restrictively: in case of inspection, the burden of proof falls on the company, which must demonstrate that driving was not the driver’s main activity. The circular adopts the criterion of recital 10 of Directive (EU) 2022/2561, under which driving is generally not the main activity when it takes up less than 30% of the rolling monthly working time. The exemption does not apply if the driver was hired as a driver, nor if someone employed as a site worker or warehouse worker in fact drives predominantly or exclusively. For doubtful cases it is advisable to seek a prior opinion from the labour inspectorate or to consult a specific scenario with a consultant.

Occasional international trips: the decision to make

For many Italian SMEs the dilemma is this: “my fleet is mostly domestic, but 2-3 trips a month we do to France or Slovenia. Should I upgrade the entire fleet or concentrate foreign trips on one or two dedicated vehicles?”.

The answer depends on three variables: number of foreign trips per year, fleet size, predictability of the domestic/international mix.

Path A — Dedicating 1-2 vehicles to foreign routes

A subset of vehicles is identified to be upgraded to G2V2 (driver cards, installation, driver training) and foreign activity is managed only with those. Savings: all other vehicles remain outside the regime.

When it makes sense: fewer than 50-80 foreign trips per year, fleet structured around repetitive runs, ability to plan cross-border trips in advance.

Hard costs: ~€1,500-2,500 + VAT G2V2 installation per vehicle (indicative range, to be verified with real quotes), ~€40 driver card per driver involved, biennial calibration €150-200 + VAT.

Path B — Upgrading the entire fleet

The G2V2 is installed on every >2.5 t MAM van, regardless of trip mix. Advantage: full operational flexibility, any vehicle can perform any trip.

When it makes sense: fleet that frequently alternates domestic and international, difficulty in planning the mix in advance, foreign volumes above ~100 trips per year.

Cost to consider: investment multiplied by the number of vehicles, but also a strategic asset in the medium term. Tachograph data, once collected, feeds automatic planning and fleet analysis: see our deep dive on how to integrate G2V2 data into fleet management.

Simplified break-even calculation

For a first-approximation decision: if the cost of installation on a vehicle does not pay back in flexibility margins within 24 months, path A is preferable. If foreign trips vary over time or grow, path B is more robust.

Summary table of most frequent cases

What to do now

1. Identify at-risk vehicles: cross MAM >2.5 t with the international/cabotage trip mix of the last 12 months.
2. Decide on strategy: dedicated vs. entire fleet. Don’t postpone the decision: installation requires 6 weeks of lead time for workshop booking.
3. Document mixed cases: every exception (e.g. own-account use with non-principal driving) must be supported by internal documentation justifying the classification.
4. Check contracts with customers: if you accept occasional cross-border trips, consider renegotiating to cover the compliance cost.
5. Bring the constraints into planning: from 1 July, driving times and breaks are no longer just a compliance topic but an operational constraint on every route. Delivery route planning software applies them automatically, together with time windows and vehicle capacity.

For the complete roadmap download our Mobility Package Compliance Checklist 2026. For specific penalties and practical non-compliance cases see the dedicated article on tachograph penalties and FAQ for vans in 2026.

In summary

• Cabotage on 2.5–3.5 t vans is limited to 3 operations in 7 days following an inbound international transport, with a 4-day cooling-off.
• A single cabotage operation triggers the G2V2 tachograph obligation on the vehicle involved.
• International own-account transport is not automatically exempt: from 1 July 2026 it falls under the obligation when driving is the main activity of the person driving.
• Residual exemptions exist for own account with non-principal driving, but are restrictive and place the burden of proof on the company.
• For occasional foreign trips, the choice is between dedicating 1-2 vehicles or upgrading the entire fleet: it depends on trip volume and predictability of the mix.

Frequently asked questions

The next step

For specific cases or mixed fleets with complex exposure, book a free 20-minute audit with an Optivo expert: together we will check your vehicles and trips and help you choose the most rational adjustment strategy.