If your staff drive for you, you have a duty of care. It does not depend on owning the vehicle.

For most organisations, the highest-risk thing their people do on the company's behalf is drive. The obligation that follows does not turn on whether you own the vehicle, employ the driver full time, or call any of it a fleet. It attaches to the driving being done for you. A charity with two pool cars, an estate agency whose staff use their own, a manufacturer whose engineers drive between sites — all in scope, and very few of them with anybody whose job this actually is.

The obligation is not, in practice, a hard one to meet. It is to know that the people driving for you are entitled to, to know it currently rather than historically, and to be able to show that you knew. What makes it fail is almost never intent. It is that the check is a task with no owner, no deadline and no consequence for skipping it, competing every week against tasks that have all three.

The evidence half is the part most organisations discover late. After an incident, the question put by an insurer, a regulator or a claimant's solicitor is not whether you have a policy on driver licensing. It is what you knew about that specific driver on that specific day, and whether you can produce it. A policy document is not an answer to that question. A timestamped record of the check is.