24. 10. 2026

A truck not owned by the carrier: a draft order requires a temporary registration certificate

The Ministry for Restoration, Infrastructure and Transport has prepared a draft order amending the Rules for the Carriage of Goods by Road. If a carrier operates a truck that it does not own — under a lease, leasing or loan agreement — it will be obliged to have a temporary registration certificate for that vehicle. Important: this is still a draft, not rules in force.

In short:

the carrier must have a temporary registration certificate if the truck is not its property and the right of use has been transferred to it in the established manner;
during carriage, the driver must have a registration certificate or a temporary registration certificate;
a medical book remains mandatory only for the carriage of food products;
during roadside inspections, Ukrtransbezpeka will accept a temporary certificate instead of a registration certificate;
the order will enter into force on the day of its official publication; the draft provides for no separate transition period.

What they propose to change

Currently, the Rules for the Carriage of Goods set separate requirements for the carrier and the driver mainly for specific goods — household, food and perishable goods. The draft makes them general for all freight transport.

A road carrier will be obliged to:

have documents for carriage in accordance with road transport legislation;
have a temporary registration certificate if the vehicle is not its property and the rights of use have been transferred to it in the established manner;
for specific goods — provide specialised and appropriately equipped rolling stock.

What documents the driver must have

Under the draft, the driver (forwarder) must have:

a driver’s licence of the relevant category;
a vehicle registration certificate or a temporary registration certificate;
a personal medical book with medical examination results — only when carrying food products;
the documents checked during Ukrtransbezpeka roadside inspections (under the list approved by Order No. 703 of 16 April 2025).

Corresponding changes are also made to the list of items checked during roadside inspections: a temporary registration certificate will appear in it next to the registration certificate.

Why this is needed

In the explanatory note, the ministry explains: the vehicle register shows the owner, but it is not always clear which carrier actually performed the carriage. Because of this, fines are sometimes imposed on truck owners, who then have them cancelled in court.

According to Ukrtransbezpeka, in 2024–2026 more than 2,300 cases were considered concerning carriers that operated vehicles under lease, leasing or loan agreements without a temporary registration certificate. The aim of the changes is to clearly identify the carrier that committed the violation and to counter illegal freight transport.

What to do now

Until the order is adopted, the current rules apply. But if you operate a truck that is not registered to your company, it is worth checking now whether you have a temporary registration certificate. It is issued by an MIA service centre at the request of the vehicle owner. We will follow the draft and update this news when the order is adopted.