Braking performance assessment: what changed in April 2025

The braking requirements that apply to your safety inspections came into force on 28 April 2025, and DVSA published them ahead of that date. The 5 November 2024 revision of the Guide to maintaining roadworthiness added a forward-dated section, recorded in its change note as "added new section '5.3a Braking performance assessment from April 2025'." The 28 April 2025 revision folded that content into section 5.3, and its change note lists "section 5.3. Braking performance assessment, clarified requirements". There is no 5.3a in the current guide. Section 5.3 as it now stands is the April 2025 braking regime.

That is why this page exists. Guidance, workshop procedures and articles written before 28 April 2025 may not reflect what section 5.3 now says. If your brake testing procedure predates the revision, section 5.3 is what it needs to be checked against.

In outline: every safety inspection is expected to include a brake performance assessment; DVSA describes a laden brake test on a calibrated roller brake tester as the most effective method of measuring braking performance; where EBPMS is not used, a minimum of four laden brake tests spread evenly across the year is expected, subject to a qualifier set out below; and where a laden test is not carried out and no EBPMS evaluation is available, a risk assessment by a competent person is required.

What DVSA expects at every safety inspection

DVSA frames the baseline as an expectation:

"To follow best practice and comply with legislation there is an expectation that every safety inspection will include a brake performance assessment using either a roller brake test (RBT), a suitable electronic braking performance monitoring system (EBPMS) or a decelerometer with temperature readings."

The passage above does not use "must", which section 1.1 reserves for a direct legal requirement set out in legislation. The assessment at every safety inspection is therefore stated as an expectation. Section 5.3 does state a "must" about the operator's own satisfaction with the method, and it points at legislation:

"Operators must satisfy themselves that the methods used to assess brake performance are sufficient to meet the requirements of Regulation 18 of The Road Vehicles (Construction and Use) Regulations 1986."

Regulation 18 of the Construction and Use Regulations is the standard the method has to be good enough to meet, and satisfying yourself of that is stated as the operator's duty.

The three methods in that expectation sentence are not the whole list. Section 5.3 names a fourth device alongside the roller brake tester:

"Conducting a laden brake test using a calibrated roller brake tester is the most effective method of measuring individual and overall braking performances. A plate brake testing device may also be suitable depending upon the design of the equipment."

So a plate brake testing device may also be suitable, depending on the design of the equipment, and it appears again where the guide deals with evidence: a signed printout of the brake performance test "from either the RBT, plate tester or decelerometer" should be attached to the safety inspection record.

There is one thing to be aware of if you use DVSA's own paperwork. Annex 4a, the specimen safety inspection record for HGVs and trailers, gives three method boxes in its braking performance assessment section - roller brake test, decelerometer test plus temperature, and EBPMS - and no box for a plate brake tester. That form is an example, not a prescribed document: section 1.4 says the safety inspection form "can be any format as long as the mandatory items listed in Section 1 of this guide are included on the form".

Laden roller brake tests

DVSA's own assessment of the methods is in the passage above: a laden brake test on a calibrated roller brake tester is "the most effective method of measuring individual and overall braking performances". The measurement covers both halves of the job - each brake individually, and the vehicle as a whole.

The practical objection to laden testing is the loading. Section 5.3 answers it with a window:

"Vehicles can be presented for roller brake testing up to 14-days before the safety inspection date; this allows the operator the flexibility to conduct a laden brake test during normal operational activities without the need to specially load it. In these circumstances the RBT report needs to be provided to the person conducting the safety inspection. A copy of the RBT report generated must be retained on the vehicle's maintenance file."

Two further points sit in that passage, and DVSA does not phrase them alike. The RBT report "needs to be provided to the person conducting the safety inspection" - a test done a fortnight earlier is only of use to the inspection if the person doing the inspection has the figures in front of them. Retaining it is stated as a "must": "A copy of the RBT report generated must be retained on the vehicle's maintenance file."

Across the year, section 5.3 sets a general expectation for operators not using EBPMS:

"Where EBPMS is not used, it is expected there will be a minimum of four laden brake tests spread evenly across the year, this can include the annual test."

That expectation does not stand on its own. Section 5.3 also deals with operations where a laden test cannot be achieved, and permits a different pattern there:

"Where this cannot be achieved, unladen RBTs should be conducted unless the construction or weight of the vehicle prevents this. Where deemed appropriate by a competent person, a minimum of four unladen RBTs can be conducted in the year, this may include the annual test, a decelerometer test with temperature readings can be carried out at other times where appropriate."

So four laden brake tests a year is DVSA's general expectation, not an absolute floor. Where a laden test cannot be achieved and a competent person deems it appropriate, "a minimum of four unladen RBTs can be conducted in the year", with "a decelerometer test with temperature readings can be carried out at other times where appropriate". That route is not a free choice: the reasons for taking it have to be recorded, and the section below sets out what that involves. Neither figure is a legal minimum. The four laden tests are what "is expected", and the unladen alternative is what "can be conducted" where a competent person deems it appropriate.

DVSA works the arithmetic through in its own examples. On a 12-week inspection cycle the two numbers coincide:

"In this example trailers not fitted with EBPMS, should undergo a laden brake test at every inspection. This is dictated by the 12-week safety inspection period and the expectation for 4 laden brake tests evenly spaced throughout the year."

In another of DVSA's examples the laden tests fall on some inspections and not others:

"To satisfy the requirement for 4 laden brake tests evenly spaced throughout the year, the operator carries out a laden brake test at least every other safety inspection. The operator may complete a risk assessment and evaluates this at the other safety inspection. The risk assessment criteria must be satisfied, and braking performance must be assessed using either an unladen brake test or where appropriate, by using a decelerometer with temperature measurement."

Section 5.3 also states a "must" for a laden roller brake test where braking performance problems have already shown up:

"Where operators experience problems with braking performance either at annual test, roadworthiness inspections or through operational performance, a laden roller brake performance test must also be carried out to confirm the brakes are performing satisfactorily before the vehicle can be considered as roadworthy. The results of this brake test must be kept as evidence of repair with the operator's maintenance documentation."

EBPMS

An electronic braking performance monitoring system displaces the four-laden-tests expectation, which section 5.3 frames as applying where EBPMS is not used. Its scope is narrow:

"At present, EBPMS is only available for use on trailers."

So EBPMS is not an option for a rigid vehicle or a tractor unit. For those, the assessment falls to the other methods DVSA names - a roller brake test, a plate brake testing device where its design suits, or, for a vehicle without a trailer or one that cannot be tested on an RBT, a decelerometer with temperature readings.

EBPMS does not remove work from the safety inspection so much as change what the work is:

"If using EBPMS to monitor brake performance, there must be an evaluation of the performance report before every safety inspection by a competent person who can interpret the data. The evaluation must be signed, dated, and attached to the vehicle record together with the performance data report. The evaluation and data report may be a single document."

The evaluation itself, its timing, the competence of the person doing it, and the signing, dating and attachment are all stated as musts. Producing the report is not the step - reading it is. The one concession is permissive: the evaluation and the data report may be a single document, so this need not be two pieces of paper.

A trailer running on EBPMS is not expected to have a laden brake test as a matter of course, but section 5.3 names two circumstances where one is still needed:

"Trailers fitted with EBPMS would only require a laden brake test if there was insufficient data to produce a report to confirm the correct operation of the system or where work has been carried out on the braking system that may have affected braking performance."

Insufficient data is the circumstance worth planning for, and the guide names the consequence rather than leaving it open: a trailer whose data is insufficient to produce a report confirming the correct operation of the system would require a laden brake test. Where a satisfactory EBPMS evaluation report is not available, a risk assessment must be completed by a competent person as well - but section 5.3 attaches an expectation to that route, that "every attempt must be made to conduct a laden roller brake test". The risk assessment is the documented fallback, not a routine substitute for the test.

Decelerometers

A decelerometer is one acceptable route, for vehicles that run without a trailer and for vehicles that cannot be tested on an RBT:

"It is acceptable to use an approved and calibrated decelerometer to measure overall brake performance values for vehicles without trailers or for vehicles that cannot be tested on an RBT. A decelerometer will measure the overall brake performance but it may not identify individual braking issues. Decelerometers cannot be used for testing trailer brake performance."

Two limits sit in that passage. The first is diagnostic: it measures the overall brake performance but "may not identify individual braking issues", so a single weak brake can hide inside an acceptable overall figure. The second is categorical - "Decelerometers cannot be used for testing trailer brake performance." A trailer's brakes have to be assessed some other way.

The temperature readings are what compensate for the first limit, and they are not an optional extra: DVSA's expectation sentence names "a decelerometer with temperature readings", not a decelerometer on its own.

"A temperature check needs to be carried out before and after the decelerometer test to help identify if individual brakes are operational. Final brake temperature readings need to be significantly higher than the initial readings to properly assess the brake performance, with relatively consistent readings taken for each brake across an axle."

Both halves matter. Final readings that are not significantly higher than the initial ones, or one brake on an axle running noticeably cooler than its opposite number, are what the check exists to expose.

When a laden test isn't possible

Section 5.3 lists categories of vehicle where laden brake assessments may not be possible or where additional loading would be difficult. That list comes with both a qualification and a duty:

"Vehicles where laden brake assessments may not be possible or where additional loading would be difficult are listed below (this is not an exhaustive list), however where possible every attempt must be made to conduct a laden roller brake test."

The categories DVSA lists are:

unladen tri-axle semi-trailers (ULTAST) - trailers running at less than 65% of permitted axle weights more than 70% of the time
vehicles running at less than 65% of permitted axle weights more than 70% of the time, which may include car transporters
ADR work, only when the load is considered dangerous and specialist facilities are not available
livestock carriers
noxious load carriers
furniture removal vehicles
vehicles operating at 50% or more of permitted axle weights when unladen
vehicles where the construction or weight prevents use of an RBT

The list is expressly "not an exhaustive list", so an operation that does not appear on it is not thereby excluded - but the reasons still have to stand up. Where it is not possible to carry out an RBT, or not appropriate to conduct a decelerometer test, section 5.3 returns to the same legislative test: "operators must satisfy themselves that the methods used to assess brake performance are sufficient to meet the requirements of Regulation 18 of the Construction and Use Regulations."

Two conditions set the limits of what the list allows. The first is that the reasons have to be documented and owned:

"Where these acceptable reasons are used, they must be detailed as part of the risk assessment and the operator must be satisfied the reasons are appropriate for their operation."

The second is that the assessment itself is unaffected:

"There is still a requirement to carry out a braking performance assessment and an assessment of the braking components at every safety inspection."

Being on the list changes the method, not the duty. The braking performance assessment and the assessment of the braking components are still required at every safety inspection. Where a laden test cannot be achieved, DVSA says unladen RBTs "should be conducted unless the construction or weight of the vehicle prevents this", and its worked examples give the ways it can be achieved: "There is still a requirement to complete a brake performance assessment at every inspection, this can be achieved with an unladen brake test or where appropriate, by using a decelerometer with temperature measurement." Where a vehicle's construction or weight prevents use of an RBT, and a decelerometer test is not possible or appropriate either, what is left is the Regulation 18 test quoted above.

The risk assessment

The risk assessment is what carries the weight when a laden test is not done. It is a "must", and it names who has to do it:

"A risk assessment must be completed by a competent person who understands braking systems and components when a laden brake test is not conducted or EBPMS is not available. For these purposes, competence can be described as the combination of training, skills, experience, and knowledge that a person has and their ability to apply them to perform a task safely."

Competence is defined by capability rather than job title - "the combination of training, skills, experience, and knowledge that a person has and their ability to apply them to perform a task safely". Whoever completes it needs to understand braking systems and components, and be able to apply that understanding to this vehicle and this operation.

The assessment is a live document rather than a one-off:

"The risk assessment must be evaluated at every safety inspection where a laden brake test is not completed, or where an EBPMS evaluation is not available."

"Where it is anticipated that there will be no change in the use of the vehicle during a twelve-month period a single risk assessment may be used. Any change in use would require an updated risk assessment."

A single assessment can cover twelve months, but only where no change in the use of the vehicle is anticipated across that period - and it still has to be evaluated at every safety inspection where a laden test is not completed or an EBPMS evaluation is not available. A change in use requires an updated one. So the document may last a year; the act of evaluating it recurs every time the circumstances that triggered it recur.

"Risk assessments must be retained with the vehicle maintenance documents for 15 months and produced if required."

DVSA sets out what the assessment "should consider". The list is:

the age and type of vehicle
the recommendations of the vehicle manufacturer
the nature of the vehicle's load, the equipment and fittings it carries or supports
the type and range of operations on which the vehicle is likely to be engaged
the type of terrain and the nature of the environment in which the vehicle operates or is likely to operate
the distance and speeds at which the vehicle travels and the journey times
previous inspection brake performance results
previous inspection brake system and component condition
acceptable reasons for not carrying out a laden brake assessment

The first six are the same factors DVSA sets out for choosing a safety inspection interval, so a fleet that has worked through setting its interval already has most of the material. The last three are what make it a brake risk assessment: the vehicle's own brake history, the condition of its brake components at previous inspections, and the reason a laden test is not being done.

Passenger carrying vehicles

Section 5.3 sets a different baseline for PCVs:

"It is expected that an unladen RBT will be conducted at every safety inspection. When the operator has assessed the risks and deems it appropriate to conduct decelerometer assessments, they must carry out a minimum of four roller brake tests spread evenly across the year (this can include the annual test)."

So for a PCV, an unladen RBT at every safety inspection is what DVSA expects. Where the operator has assessed the risks and deems it appropriate to conduct decelerometer assessments instead, they must carry out a minimum of four roller brake tests spread evenly across the year, and the annual test can count towards that. The risk assessment travels with the decelerometer route here as well:

"Where a decelerometer test, with temperature checks has been conducted, a risk assessment must be completed and retained on file. Where there will be no change in the use or condition of the vehicle during a twelve-month period, a single risk assessment may be used. Any change would require an updated risk assessment."

Recording and reviewing it

The safety inspection record itself should show three things:

"The safety inspection record should indicate the date of the assessment, how the braking performance was assessed and whether the vehicle or trailer was laden."

Date, method, and laden or unladen. The method field is doing real work: a record showing an unladen test in a year that also needs laden ones is what tells you, months later, whether the pattern across the year was met.

Then the evidence:

"A signed printout of the brake performance test from either the RBT, plate tester or decelerometer should be attached to the safety inspection record. If the brake test equipment cannot produce a printout, the test results (including temperature readings where applicable) must be recorded by the inspector on the safety inspection report."

The two halves of that carry different force. Attaching the signed printout is a "should"; where the equipment cannot print, recording the results on the report is a "must". Under the guide's own convention in section 1.1, "must" is "a direct legal requirement set out in legislation" and "should" is best practice, "strongly recommended that you do unless you can demonstrate that an alternative approach provides a similar level of compliance". Between them the two sentences cover both cases: the printout where the equipment produces one, the inspector's written results where it does not.

Attaching the printout is not the end of it:

"It is essential that brake test reports are reviewed and understood to ensure the brakes are working correctly and meet the required standards for roadworthiness."

DVSA's word there is "essential", which is not one of the two modal tiers the guide defines - "must" for a direct legal requirement, "should" for best practice. It is strong expectation language rather than a stated legal requirement. The hard obligations sit either side of it: for EBPMS, the signed and dated evaluation by a competent person before every safety inspection, quoted above; and for the inspection record as a whole, section 1.5 - "The transport manager or responsible person must have access to and review the completed safety inspection sheet or electronic record before the vehicle returns to service."

The practical consequence does not turn on how "essential" is classified. Uploading a brake test PDF, or filing a printout, is not the compliance step. Both of the musts above require someone to read: the EBPMS evaluation by a competent person who can interpret the data, and the section 1.5 review of the completed record before the vehicle returns to service. Between them, someone forms a view that the brakes meet the standard whatever weight "essential" carries on its own. It is an act of judgement, not an act of filing. DVSA also publishes separate guidance on interpreting roller brake test reports, referred to in section 5.3 as "understanding your HGV or trailer's brake test report".

Where the records are held electronically, section 4.6's requirements apply to brake test evidence as to anything else: "there must be a clear end-to-end audit trail", "it must be clear what's been checked and by whom", and "The records must show a clear audit trail from inspection to sign-off after repair (if one is needed)." Risk assessments must be retained with the vehicle maintenance documents for 15 months, a copy of the RBT report must be retained on the vehicle's maintenance file, and where a laden test follows a braking performance problem, those results must be kept as evidence of repair.

Frequently asked questions

Is a laden roller brake test legally required at every safety inspection?

No. DVSA states an expectation that every safety inspection will include a brake performance assessment, using a roller brake test (RBT), a suitable electronic braking performance monitoring system (EBPMS) or a decelerometer with temperature readings - and section 5.3 names a plate brake testing device as possibly suitable too, depending upon the design of the equipment. Where a laden roller brake test is not carried out with the safety inspection and no satisfactory EBPMS evaluation report is available, a risk assessment must be completed by a competent person, and DVSA states an expectation that every attempt must be made to conduct a laden roller brake test.

How many laden brake tests a year does DVSA expect?

Where EBPMS is not used, it is expected there will be a minimum of four laden brake tests spread evenly across the year, and this can include the annual test. That is an expectation rather than a legal minimum, and it carries a qualifier: where a laden test cannot be achieved and a competent person deems it appropriate, a minimum of four unladen RBTs can be conducted in the year, with a decelerometer test with temperature readings at other times where appropriate. Where those acceptable reasons are relied on, they must be detailed as part of the risk assessment.

Can EBPMS be used on a rigid vehicle or a tractor unit?

No. DVSA states that at present, EBPMS is only available for use on trailers. Where it is used, there must be an evaluation of the performance report before every safety inspection by a competent person who can interpret the data, and that evaluation must be signed, dated and attached to the vehicle record together with the performance data report.

Can a decelerometer be used to test trailer brakes?

No. DVSA states that decelerometers cannot be used for testing trailer brake performance. A decelerometer is acceptable for vehicles without trailers or for vehicles that cannot be tested on an RBT; it measures the overall brake performance but may not identify individual braking issues, and a temperature check needs to be carried out before and after the test.

How long does a brake risk assessment last?

It is not a one-off. The risk assessment must be evaluated at every safety inspection where a laden brake test is not completed, or where an EBPMS evaluation is not available. Where it is anticipated that there will be no change in the use of the vehicle during a twelve-month period a single risk assessment may be used, and any change in use would require an updated risk assessment. Risk assessments must be retained with the vehicle maintenance documents for 15 months.