Bus driving licences: categories D1 and D, and the ages that gate them

Two documents decide whether a person may take a bus out of the depot, and they are issued under different instruments by different processes. The driving licence category says which vehicle the holder may drive. The certificate of professional competence says the holder has the qualification Directive (EU) 2022/2561 requires to drive it in road transport, outside the exemptions in that directive’s Article 2, such as non-commercial carriage of passengers. The ages at which the pair can be held are not one number, and both instruments that set them are changing.

The four passenger categories

Directive (EU) 2025/2205, the new driving licence directive, lists the categories in Article 6(1)(c). Points (viii) to (xi) are the passenger ones.

Under Article 4(4)(h) and (j) of Directive 2006/126/EC, the text applied today, vehicles in D1 and D may be combined with a trailer having a maximum authorised mass not exceeding 750 kg. Directive (EU) 2025/2205, from 26 November 2029, refers instead to a trailer of category O1, which Article 4(1)(c)(i) of Regulation (EU) 2018/858 defines as a trailer of maximum mass not exceeding 0.75 tonnes. Anything heavier moves the combination into D1E or DE.

None of the four stands alone. Article 9(1) issues BE, C1, C1E, C, CE, D1, D1E, D and DE only to drivers already entitled to drive category B vehicles, so a bus category is always an addition to a car licence; Article 6(1) of Directive 2006/126/EC, the text applied today, goes further and issues D1E and DE only to drivers already entitled to D1 and D respectively. The equivalences in Article 9(2) of the new Directive, applied from 26 November 2029, then run downwards: a DE licence is also valid for D and D1 under point (d), and for D1E combinations under point (e).

The 8-metre ceiling on D1 is a licence limit, not a construction limit. It does not track the type-approval classes of UN Regulation No. 107, which sort vehicles by passenger capacity and by provision for standing passengers and are explained in bus classes. The two schemes cut the field at different points. Classes I, II and III exist only above 22 passengers in addition to the driver (paragraph 2.1.1), which is already past the 16-passenger ceiling of D1, so a vehicle in any of those three is always a category D vehicle whatever its length. It is Classes A and B, at 22 passengers or fewer (paragraph 2.1.2), that straddle the line. On those two definitions a Class B vehicle is a D1 vehicle carrying 16 passengers in a body under 8 metres, and a category D vehicle carrying 20, or carrying the same 16 in a body 8.5 metres long.

The second document

The licence is the vehicle side. The qualification side is Directive (EU) 2022/2561, which covers drivers of vehicles requiring a D1, D1+E, D or D+E licence and grants a certificate of professional competence at two grades. Article 6(1) is the standard initial qualification, and it reaches the driver in whichever of two forms the Member State has picked, because Article 3(1)(a) makes them alternatives the State chooses between rather than options the driver has. The first, course attendance plus a test, is point (a) of Article 6(1) and runs through Annex I, Section 2.1: 280 hours, including at least 20 hours of individual driving, of which at most eight may be on special terrain or a top-of-the-range simulator. The second, tests only, is point (b) and runs through Section 2.2, which sets no course hours at all — a theoretical test of at least four hours, and a practical test made of a driving test with a minimum duration of 90 minutes — from which up to 30 minutes may be deducted where the driver also takes the optional test on special terrain or a top-of-the-range simulator — plus at least 30 minutes on loading, passenger comfort and safety, crime prevention, physical risk and emergency situations, which are points 1.5, 1.6, 1.7, 3.2, 3.3 and 3.5 of Section 1. Article 6(2) is the accelerated qualification, itself optional for the Member State under Article 3(2): 140 hours under Section 3, at least 10 of them individual driving, of which at most four may be on special terrain or a top-of-the-range simulator. For a driver who already holds a CPC for goods and moves to passengers (Article 5(5)), Sections 2.1 and 3 set 70 and 35 hours instead. All of them then require periodic training, “35 hours every five years” under Annex I, Section 4, the first course falling due within five years of the CPC, a period Article 8(2) lets a Member State shorten to three years or extend to seven; only after that first course does Article 8(3) set the five-year cycle. Those hours are set out in the operating obligations of a bus fleet, and the exemptions that lift the requirement altogether in Driver CPC explained.

The certificate is shown by Union code 95, which Article 10(1) of Directive (EU) 2022/2561 has the competent authorities mark alongside the corresponding categories either on the driving licence or on a driver qualification card. In Annex I, Part E of Directive (EU) 2025/2205 the code reads “Driver holding CPC, meeting the obligation of professional aptitude provided for by Directive (EU) 2022/2561 until …”, the Annex’s own worked example being 95(01.01.2028). Great Britain publishes its own Driver CPC rules for lorry, bus and coach drivers, set out in Driver CPC in Great Britain.

What binds today

Directive 2006/126/EC is still in force; EUR-Lex shows it as “In force: This act has been changed. Current consolidated version: 01/11/2020”. Its Article 4(4) fixes the minimum age for categories D1 and D1E at 21 years in point (i), and for categories D and DE at 24 years in point (k). Article 4(7) then derogates from those ages: the minimum age for issuing a licence in categories D1 and D1E, and D and DE, “shall be the minimum age prescribed for the driving of such vehicles for holders of a CPC” in Directive 2003/59/EC — the CPC directive that Directive (EU) 2022/2561 codified and repealed, its Article 14 reading references to the old text as references to the new.

There the answer has two layers, because the provision has already been rewritten once. Article 27, point (b), of Directive (EU) 2025/2205 replaced Article 5(3) of Directive (EU) 2022/2561 outright — “paragraph 3 is replaced by the following” — and the EUR-Lex record for the CPC directive dates that replacement from 25 November 2025. But Article 29(1) of the new Directive gives Member States until 26 November 2028 to adopt the measures necessary to comply with it and requires them to apply those measures from 26 November 2029, and Article 27 carries no earlier date of its own. Until then it is national law transposing the pre-amendment wording that binds a driver, and the only consolidated version EUR-Lex lists for Directive (EU) 2022/2561 is dated 23 December 2022, so the text it serves for that directive is still the pre-amendment one. In that version three thresholds apply rather than one. From 21, with the accelerated CPC of Article 6(2), a driver may take D1 and D1+E vehicles, and D and D+E vehicles only “to carry passengers on regular services where the route does not exceed 50 kilometres”. From 21, with the standard CPC of Article 6(1), the same driver may take D and D+E vehicles without that distance condition. And from 23, the accelerated CPC opens D and D+E generally. Two national options sit underneath: a Member State may authorise the first group from 18 on its own territory with an Article 6(1) CPC, and the second from 20, which “may be reduced to the age of 18 where the driver drives such vehicles without passengers”.

The practical shape of that is a 21-year-old with the accelerated CPC confined to D1 and D1+E vehicles and to regular services on routes not exceeding 50 kilometres until the age of 23 — two more years, our arithmetic.

What changes, and when

Directive (EU) 2025/2205 was published at OJ L, 2025/2205 of 5 November 2025 and EUR-Lex records it as “In force”. Article 31 sets entry into force on the twentieth day following publication, which puts it at 25 November 2025 — our arithmetic. Article 30(1) repeals Directive 2006/126/EC with effect from 26 November 2029, except for its Article 6(4), point (c), repealed with effect from 26 November 2027; Article 30(2) repeals Regulation (EU) No 383/2012 from the same 2029 date. Until then the old directive stays in force, save for that one point.

Article 29 sets the timetable. Member States adopt and publish the measures necessary to comply by 26 November 2028 and apply them from 26 November 2029, with two exceptions: the alternatively fuelled vehicle equivalences in Article 9(2), points (j) and (k), are adopted and applied from 26 November 2027, and the accompanied driving scheme in Article 17 from 26 November 2028. Article 27, which rewrites the CPC directive, is given no separate date, so the measures transposing it fall under the general one.

Both halves of the age question move together. On the licence side, Article 7(1)(f) keeps 24 years for D and DE, and point (g) sets 21 years for D and DE “provided that the driver holds a CPC as referred to in Article 6(1) or 6(2) of Directive (EU) 2022/2561” — either grade, not only the standard one. On the qualification side, the Article 5(3) that Article 27 has already substituted into Directive (EU) 2022/2561 carries a single age: from 21, with a CPC under Article 6(1) or (2), a driver may take D, D+E, D1 and D1+E vehicles. The 23-year threshold disappears outright, and the 50-kilometre condition disappears from that general rule. In place of the threshold, Member States may set up a monitoring scheme for drivers under 23 holding an accelerated CPC, and where such drivers are required to attend road-safety periodic training before turning 23, that attendance counts towards the 35 hours. Recital 50 states the intent plainly: the conditions for driving a bus of category D or DE from a certain age following professional qualification “should be simplified, without compromising road safety”.

The 50 kilometres survive one level down, in the national derogations. The second subparagraph of the replacement Article 5(3) lets a Member State authorise D1 and D1+E on its own territory from 18 with an Article 6(1) CPC; the third lets it authorise D and D+E from 20 on the same CPC, and says this “may be reduced to the age of 18 to drive such vehicles without passengers, or to carry passengers on regular services where the route does not exceed 50 kilometres”. Neither 18-year route for D and D+E is new: in the version still applied today, point (a)(i) lets a Member State authorise the 50-kilometre regular services, together with D1 and D1+E, from 18 with an Article 6(1) CPC, and point (a)(ii) lets the age of 20 be reduced to 18 where the vehicle is driven without passengers. The replacement gathers the two into one subparagraph. Those are the restrictions the licence directive incorporates: Article 7(2), point (e), lets a Member State go down to 18 for D1, D1E, D and DE where the driver holds an Article 6(1) CPC, and point (e)(ii) makes D and DE subject to that same third subparagraph — the no-passengers or 50-kilometre pair. Point (f) allows 20 for D and DE with an Article 6(1) CPC.

A licence issued young stops at the border

The territorial limit already binds today. Where a Member State authorises driving from a lower age under the national options of the CPC directive, the second subparagraph of Article 4(7) of Directive 2006/126/EC limits the licence to the territory of the issuing Member State “until such time as the licence holder has reached the relevant minimum age referred to in the first subparagraph of this paragraph and holds a CPC”.

From 26 November 2029 the rule sits in Article 7(4) of Directive (EU) 2025/2205. Licences issued under the derogations in paragraphs 2 and 3 are valid only on the territory of the issuing Member State until the holder reaches the minimum age set out in paragraph 1, after which they are valid throughout the Union. Other Member States may recognise licences issued below the paragraph 1 ages — but the second subparagraph states that they “shall not recognise the validity of driving licences issued under paragraph 2, points (b), (e) and (f)”. Points (e) and (f) are the bus derogations. Under the new text, a driver licensed under either of them is therefore a domestic driver by law until the paragraph 1 age is reached.

What does not change

Administrative validity stays at five years, and stays a default rather than a fixed term. Article 7(2)(b) of Directive 2006/126/EC gives categories C, CE, C1, C1E, D, DE, D1 and D1E five years where the car categories get ten, or up to 15 at a Member State’s choice; Article 10(2)(b) of the new Directive repeats the five, while setting the car categories at 15, reducible to 10 where national law lets the licence serve as an identity document. Both then let a Member State go shorter, but only the old directive names category D when it does. Article 7(3) of Directive 2006/126/EC allows a licence issued to a novice driver in any category to be limited, allows the first licence issued to a novice driver in categories C and D to be limited to three years, allows any individual licence to be limited where an increased frequency of medical checks or other specific measures such as restrictions for traffic offenders is needed, and allows a reduction for holders who have reached 50. Article 10(2) of Directive (EU) 2025/2205 keeps the architecture but drops the category-specific limb and the three-year figure with it, moves the age, and adds one power. Its powers to shorten are a limit for novice drivers in any category, naming no period; a limit on individual licences where an increased frequency of medical checks, self-assessments or other specific measures, including restrictions for traffic offenders, is needed; a reduction from 65; and a reduction for persons granted a temporary residence permit or benefiting from temporary protection, or adequate protection under national law. None of the new shortening powers names category D — in the new Article 10(2), category D appears only in the five-year period itself.

The medical grouping also stays where it is. Annex III of both directives sorts drivers into two groups, and Group 2 is the same list of eight categories. Under point 4 of Annex III to Directive 2006/126/EC, Group 2 applicants undergo medical examinations before a licence is first issued and are then “checked in accordance with the national system in place in the Member State of normal residence whenever their driving licence is renewed”. Article 11(1) of Directive (EU) 2025/2205 requires a medical examination before first issue for those categories “regardless of whether a medical examination was undertaken for another category”, and Article 11(2) requires one before renewal. The self-assessment form and national fitness-assessment system that Article 11(3) offers as alternatives are available only for categories AM, A, A1, A2, B, B1 and BE. Under both texts a bus driver’s renewal carries a medical check; the new one calls it a medical examination.

What is not extended to buses

Article 17 introduces accompanied driving from 17 years, marked with Union code 98.02, and from 26 November 2028 Member States must issue such licences for category B. Paragraph 2 allows them to extend the scheme to categories C1, C1E and C, with mutual recognition among the Member States that do. The passenger categories are not in that list, and recital 48 frames the scheme as “making the profession of truck driver more accessible”. It does not open a route into a bus at 17.

The new text has two narrow routes into a passenger vehicle without a D licence, and neither of them travels. Both are optional for the Member State, and both authorise driving only on that Member State’s own territory. Article 9(4) lets Member States “authorise the driving on their territory” of, at point (a), D1 vehicles of maximum authorised mass 3,500 kg, excluding specialised equipment for the carriage of passengers with disabilities, by drivers over 21 who have held a category B licence for at least two years, where the vehicles are used by non-commercial entities for social purposes and the driver volunteers — the route Article 6(4)(a) of Directive 2006/126/EC already allows today, “after consulting the Commission”. Where that entitlement is shown on the licence at all, the second subparagraph of Article 9(4) requires it to be shown “only by means of relevant national codes”, not the Union codes of Annex I, Part E. Article 9(5), applied from 26 November 2029, entitles Member States to authorise the driving of D or D1 vehicles “on their territories” by the holder of a category C licence; it turns on who is driving and not on the licence alone, and it does not open D and D1 vehicles to category C holders at large. The holder must be the person executing a roadworthiness test under Directive 2014/45/EU, and then only within a 5 km radius of the testing centre, or a mechanic of the repair workshop performing a test drive once the vehicle has been repaired or for maintenance or inspection purposes, within a 5 km radius of the workshop. No other person may be transported, and on leaving the centre or workshop the driver must be able to prove on inspection which of the two purposes the trip serves.

Where the threshold meets the supply

IRU reported in October 2023 that Europe had 105,000 unfilled bus and coach driver positions, 10 per cent of the total professional driver population and 54 per cent more than in 2022, and that “without action to attract and retain drivers, Europe could have more than 275,000” unfilled positions by 2028. The same release, and IRU’s current driver shortage page, put the demographic this way: fewer than 3 per cent of Europe’s bus and coach drivers are under 25 and more than 40 per cent are over 55. The 2023 release named the barrier in terms the 2025 Directive answers only in half. It called for the minimum age to be lowered in individual countries “without accompanying distance restrictions such as the 50km limit”. The Union age of 21 does arrive without one. The national route to 18 for D and D+E — and lowering in individual countries is what the release asked for — does not, because that is precisely where the replacement Article 5(3) puts the 50 kilometres.

Whether 26 November 2029 closes the gap is not a question the text can answer. What a side-by-side reading of the two versions of Article 5(3) shows — our comparison, not a statement either of them makes — is that from that date the accelerated qualification of Article 6(2) and the standard qualification of Article 6(1) reach categories D and D+E at the same age, 21, removing the two-year gap the shorter one now carries.