Code 95 administration:
a practical guide for training providers
A driver who doesn't complete 35 hours of periodic training within their five-year cycle is no longer allowed to drive professionally. Code 95 is the EU professional driver requirement, and the maths is simple. The administration around it is not. This guide walks through the complete workflow for Dutch Code 95 training providers, from intake to the CBR report, with the mistakes we see most often and how to avoid them.
The rules in one paragraph
Every driver holding a C, C1, D or D1 licence has to complete 35 hours of approved periodic training within their five-year cycle to keep driving professionally. The cycle is personal. It starts when the Code 95 is first issued or renewed, and ends on the expiry date printed on the driving licence. Modules are typically 7 hours per day (one training day), but 4-hour and 3-hour modules exist too, as do blended programmes with e-learning.
Not every course counts. Only modules approved by the CCV (the professional-driver division of the Dutch driving licence authority CBR), reported correctly by you as the training provider through TOP Internet (the CBR's reporting portal), are credited to the driver's personal balance. A missed report means zero hours, no matter how much coffee you served.
For many drivers, 2026 is the year the cycle that started in 2021 ends. Expect peak demand in Q3 and Q4. Anyone still running their admin in Excel is in for a busy September.
The full workflow for one driver
From the moment a driver or their employer registers until the moment the CCV has the hours in its system, your administration goes through eight steps. We list them below, together with where things usually go wrong.
- Registration and intake. The driver fills in name and address, date of birth, driving licence number and the Code 95 validity. The licence number has to be right. A typo means the report to TOP gets rejected later.
- Booking onto a module. A module is a specific approved course, for example "Load securing", "Digital tachograph" or "Fuel-efficient driving". The number of hours per module is fixed in the CCV approval.
- Invoice and payment. For transport companies this runs through one monthly invoice per client company. Self-employed drivers pay online straight away. Remember that payment is separate from attendance. Paid hours without actual attendance don't count.
- Attendance on the course day. This is the biggest legal pitfall. A driver who leaves after the first break but is on the attendance list doesn't get their hours. In an audit, you as the training provider are liable. A digital check-in (QR scan, biometrics or a confirmed login) holds up better than a signature on paper.
- Completing any e-learning. Blended modules (for example 4 hours online plus 3 hours in the classroom) only count once both parts are finished. Many admin errors happen when the e-learning is finished later and nobody checks again whether the balance is now correct.
- Generating the certificate. A CCV-approved certificate carries a unique number, date, module name, number of hours and the signature of the instructor or training provider.
- Reporting to TOP Internet. Within 10 working days after the course ends, you as the training provider have to report the hours through TOP Internet, or through an API connection if your software supports it. Report late and the hours don't count, even if the driver was physically there.
- Cycle overview for the driver. The driver or employer wants to see how many hours have been collected, how many are still needed and when the Code 95 expires. A driver with no view of their balance is a driver who panic-books towards the end. That driver is a planning problem for you.
The eight most common mistakes
This list comes from conversations with training providers who moved from Excel or Word to Trainiq. None of them is fatal, but together they easily cost half a day of manual work per week.
The 10-working-day deadline is hard. No excuses, no way to repair it, and the driver has to take the course again. Set a fixed slot each week (Monday morning, say) in which you report the previous week.
One digit typed wrong and the TOP report fails. Validate the number at the first booking with a check against the RDW vehicle authority database, or let the driver upload their own licence so you can check it.
Paper lists don't survive an audit. A tick added afterwards for a driver who wasn't there is almost impossible to verify. A digital check-in with a timestamp stands up much better when an inspector asks for it.
The driver does the e-learning but doesn't show up for the classroom day, or the other way round. Both have to be complete before the hours count. Make sure your system tracks both parts as one linked unit, not as separate courses.
Drivers prefer to put off their Code 95 admin until 3 months before the end date. By then, most training providers' schedules are full. Send automatic reminders at T-180 days and T-90 days, to both the driver and the employer.
Fleet managers want one screen with "which of my 60 drivers is on track, and who isn't". Emailing Excel exports back and forth is outdated and error-prone. Give the transport company its own partner portal so they can check the current status themselves.
Is the CBR doing a spot check? Then you have to show, per driver and within 24 hours, which modules were completed on which day, at which venue, with which instructor and with which attendance confirmation. A PDF export per driver, one click, is what you want.
The driver books themselves, the transport company forgets and books them too. An idempotent booking layer (at most one booking per driver per session) prevents it. In Excel, you have to police that yourself.
Excel or software?
Honestly: for a training provider with 1 to 5 active drivers, a good Excel template is fine. Three columns (driver, date, hours), one tab per year, a formula that adds up to the 5-year total. You can keep that in your head, and the TOP reports can be done by hand.
From roughly 30 drivers it breaks. The reasons we hear most often:
- Excel has no relations, so even simple questions ("which drivers took module X in 2025?") turn into filter acrobatics
- Two people can't work in the same sheet at the same time without conflicts
- There are no automated reminders, so the driver doesn't see their end date coming
- Transport companies want a live overview, not a weekly export
- CBR audit reports have to be cut and pasted together by hand
Dedicated Code 95 administration software automates the balance per driver, ties attendance to the hour count and produces an audit-ready report in one click. Whether you move to Trainiq or to another solution: if you have more than about 30 drivers, weigh it up at least once.
A practical year plan: what do you schedule when in 2026?
A rough sketch to build your planning on. Watch the peaks, because for almost every Code 95 training provider, September to December is the busiest period.
| Period | What to plan | Why |
|---|---|---|
| Q1 | Finish the 2025 cycle reporting, send T-180 reminders for cycles ending in 2026 | Early warnings give drivers time to plan |
| Q2 | Increase capacity for popular modules (load securing, tachograph) | Bookings for Q3 and Q4 come in during May and June |
| Q3 | Schedule peak sessions, send T-90 reminders, bring partner portals up to date | Transport companies decide now which drivers still need training |
| Q4 | Last-call sessions, daily TOP reports, CBR audit reports ready to go | Everyone closing their cycle in 2026 wants it done in December |
Frequently asked questions
How do I know whether a module is CCV-approved?
The CCV publishes a register of approved courses on cbr.nl. Every approved module has a unique code number that you report in TOP Internet. Non-approved courses are useful for the content but don't count towards the 35-hour cycle.
What do I do when a driver leaves halfway through the day?
Incomplete attendance means no hours. Full stop. Even if it was 80% of the day. Record it in your system, email the driver a confirmation that the hours were not credited, and offer alternative sessions. Do NOT try to be pragmatic. In an audit, this costs you your approval as a training provider.
Can a transport company book for its drivers?
Yes, and that is actually the norm. Fleet managers select modules per employee, one invoice goes to the company, certificates go straight to HR. Your training software has to support this. A self-booking link for individual drivers is useful on top of that, for the self-employed.
What if the TOP report fails?
The most common causes: wrong licence number, cycle already closed, attendance date outside the module's approval period. Keep a log line per report so that when one bounces you know why straight away. Then you can correct it within the 10-working-day deadline.
In short
Code 95 administration stands or falls with three things: reliable attendance records, timely TOP reporting and a clear view of the cycle for driver and employer. The rest (invoicing, certificates, reminders) follows from those. Get the three right and the weekly admin is done within an hour. Let them get tangled and you spend a day on it and still carry audit risk.
Trainiq automates these three and connects them to your invoicing and to a partner portal for transport companies. Want to see what it looks like at your scale? Request a free demo. We walk through your current Code 95 flow together and within 20 minutes you'll see where the time savings are.
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