If your accountant has ever said "you should probably have a grey fleet policy," and your response was a slow "we'll get to it" - I get it. Most Irish SMEs running grey fleet don't have a written policy. The Health and Safety Authority does not consider that a defence.
The HSA position is plain: under the Safety, Health and Welfare at Work Act 2005, a vehicle driven for company purposes is a place of work. Whether the company owns the vehicle or the employee does is irrelevant. The employer's duty of care is the same.
That's the bit most SMEs haven't internalised. The bit that follows from it - that you should have a written policy, signed and dated, covering specific things - is what this post is about.
Why a written policy matters
Three reasons. The first is statutory: the Safety, Health and Welfare at Work Act requires a written safety statement, and the HSA's Managing Grey Fleet information sheet is explicit that grey fleet falls under it. If an inspector asks for your safety statement and your grey fleet section is missing or thin, that's a finding.
The second is practical: when an incident happens - an accident, an insurance claim, an HR dispute over reimbursement - the policy is what you reach for. Without it, you're improvising under pressure. With it, you're following a documented process.
The third is cultural: a policy is how you set expectations with the team. Engineers, surveyors, and consultants who use their own cars for work need to know what's expected of them. A clear policy beats vague custom every time.
The seven sections every policy needs
I've reviewed grey fleet policies from a fair few Irish SMEs across engineering, surveying, and consulting. The good ones cover seven sections. The bad ones miss two or three.
1. Scope and eligibility
Who does this policy apply to, and which vehicles count as grey fleet for the purposes of the policy. The trap here is the part-time driver - the office manager who occasionally collects supplies, the marketing lead who drops off materials at events. They're using personal vehicles for work, so they're grey fleet, even if they only do it three times a year.
Spell out: "This policy applies to any employee who uses a personal vehicle for company business, regardless of frequency."
2. Driver licence and insurance verification
The two things you actually need to verify before allowing an employee to drive on company business. Licence: valid, in date, no disqualifying penalty points. Insurance: business use cover, not just social, domestic and pleasure. Most personal motor policies don't cover business use by default - the employee has to ask the insurer to add it, usually for a small annual premium.
Spell out: how often the check is done (annual is standard), who's responsible for it, and what evidence is kept on file.
3. Vehicle roadworthiness
NCT certificate within validity, valid road tax, no obvious safety defects. The HSA position is that the employer has a duty to satisfy themselves the vehicle is roadworthy, not just to take the employee's word for it.
Spell out: what evidence is required (NCT cert sighted and recorded, or a self-certification with periodic spot checks), how often, and what happens if a vehicle isn't compliant.
4. Mileage reimbursement
This is the section most policies handle reasonably well, because it's the section the finance team owns. The civil service rates apply, the year-to-date band rule applies, the engine-CC categorisation rules apply.
Spell out: the rate basis, how distances are calculated (Maps-verified, or manually with audit), the approval process, the deadline for submission, the subsistence and tolls treatment, and how project allocation works if your firm bills mileage to clients.
5. Accident and incident reporting
What the employee does if they have an accident on company business. Who they tell, when, what records they keep. The mistake most policies make here is treating it as an HR question. It's a duty-of-care question with HR, insurance, and HSA reporting implications.
Spell out: immediate steps (contact emergency services if needed, document the scene, exchange details), notification chain (line manager, HR, named accountable person), record retention, and the threshold that triggers a Reportable Workplace Accident Incident return to the HSA.
6. Driving hours and fatigue
The section most policies skip. The Working Time Act limits, the firm's expectation around long-distance driving, the policy on overnight stays vs same-day return for distant sites. If you have engineers driving from Cork to Donegal and back in a day, this is the section that says whether that's acceptable.
Spell out: maximum continuous driving expectations, when an overnight stay should be authorised in advance, and the fatigue-management responsibilities of both employee and employer.
7. Review and sign-off
Date the policy was issued, date it was last reviewed, date it's next due for review (annually is standard), and the named person responsible for it. Plus an acknowledgement section employees sign when they're issued the policy or when it's updated.
Spell out: who owns the policy, the review cadence, and the acknowledgement requirement.
What HSA inspectors actually look for
If the HSA does come in, they don't read your policy from cover to cover. They look for three things.
First: does it exist, is it dated, and is it signed by a named accountable person. A policy with no date and no owner is treated as no policy.
Second: are there documented checks. Inspectors will ask for a sample of recent licence verification records, NCT-sighted records, accident reports. If the policy says you check licences annually but you've never actually documented a check, that's a finding.
Third: do the employees know about it. Inspectors sometimes ask drivers directly. If three out of five engineers say they've never seen the grey fleet policy, that's a finding too.
The pattern: the policy itself matters less than whether it's lived. A six-page policy that nobody follows is worse than a two-page policy that everyone signs.
The common omissions
Across the policies I've reviewed, three sections get skipped most often. The driving hours section. The accident reporting chain. The annual review and sign-off. Each one is a finding waiting to happen.
The other common omission is more subtle: policies that conflate grey fleet with general expense rules. Mileage gets one paragraph in the expenses policy, and there's no separate grey fleet section. What that produces is a rate table, not a policy. The HSA wants the duty-of-care framing, separately and explicitly.
The one-page version
If you're starting from nothing, don't aim for the perfect 12-page policy. Aim for a one-pager that names the seven sections, states the firm's position on each in two or three sentences, names the accountable person, and dates the document. Get it signed. Issue it to the team.
Then over the next quarter, build out the procedural detail under each section as you actually run the checks for the first time. By month six, you'll have a real policy, lived through, with documented evidence behind every section.
Don't wait for the perfect policy. The HSA cares more that you have a process than that the document is beautiful.
If your firm wants to go further
The grey fleet category covers a lot of ground - the definition piece sets out the four fleet types and where grey fleet sits in the wider compliance picture. The mileage reimbursement section of your policy needs to play nicely with the year-to-date band rule, which is where most spreadsheet processes break down.
The bottom line
A grey fleet policy is the documented evidence that you've thought about your duty of care, you've set expectations with your team, and you have a process that survives an inspector's questions.
If you don't have one yet, the right move is a one-page version this week, properly dated and signed, with the procedural detail filled in as you actually run the checks.
If you'd like to see how the mileage-reimbursement section of a policy plays out in a working system - rate-band logic, approval chain, audit trail, ERR-ready records - book a 20-minute demo.
Last updated: 28 April 2026.
