Grey Fleet Uninsured Driving - A Major Risk Hiding In Plan Sight
If you’re a company director, HR leader or fleet manager, here’s an uncomfortable truth: You can have a well-run business and still be exposed to uninsured driving through your grey fleet - employees using their own cars for work.
That exposure is no longer hypothetical. A new Motor Insurers’ Bureau of Ireland (MIBI) update, reported on 16 February 2026, highlights that 19,673 vehicles were seized by An Garda Síochána for being driven without insurance in 2025[i].
And with the Irish Motor Insurance Database (IMID) enabling near-instant roadside checks, detection (and seizure) is becoming more systematic.
The grey fleet question directors should be asking is simple: Could any of those uninsured vehicles have been on work business when they were stopped and if so, what would that mean for us?
Why this matters more for grey fleet than company fleet
With company-owned vehicles, most organisations already have some control: fleet insurance, procurement rules, service schedules and driver authorisation.
With grey fleet, the control environment is often weaker because it relies on assumptions:
“They said they’re insured.”
“It’s their car - that’s their responsibility.”
“We reimburse mileage, so they must be compliant.”
“If they’re uninsured, that’s a personal issue.”
From a governance and duty-of-care perspective, those assumptions are risky.
The HSA is explicit that employers have a duty of care regardless of vehicle ownership and grey fleet should be managed as diligently as company vehicles.
The updated national guidance from the RSA/HSA/An Garda Síochána also reinforces that when someone is driving for work, they are operating a mobile workplace and employers must manage that risk.
The consequences
If a colleague is uninsured while on work business, you may face a “stack” of consequences that directors should recognise immediately:
People risk
Injuries and trauma to staff and third parties.
Long-tail wellbeing impacts on teams and managers.
Legal and regulatory exposure
Serious questions about your driving-for-work risk management system (policy, supervision, verification and documentation).
Increased scrutiny after an incident, especially if you cannot evidence controls.
Financial loss
Claims costs, uninsured loss recovery disputes, legal fees.
Disruption costs: investigations, reputational damage, time drain at leadership level.
Reputation and client confidence
Particularly acute for professional services, construction, healthcare, logistics and any sector that relies on trust and governance.
How does exposure happen?
In Irish organisations we commonly see five “failure points” relating to grey fleet motor insurance:
Out-of-date insurance documents: A policy existed… last year.
Wrong class of use / business use not included: An employee may be insured for social/domestic/pleasure commuting, but not business travel.
Mid-term changes not captured: Policy cancelled for non-payment, vehicle changed, named driver removed, address change, etc.
Mileage and journey integrity issues: Organisations reimburse claims without verifying that the driver/vehicle was eligible and insured at the time.
No systematic oversight: No cadence, no exception handling, no audit trail - just a once-off declaration during onboarding (if even that).
A practical response: treat grey fleet as a controlled work activity. The goal is not to “police” staff. It is to protect your people, the public and the organisation and be able to prove it. And remember, you must by law, also check driver licences are valid.
The national guidance is clear: adopt structured risk management, not informal trust.
Grey Fleet Uninsured Exposure Checklist
A) System: can you evidence compliance at any point in time?
Do you have a single system of record for grey fleet eligibility (driver and vehicle)?
Can you show who was authorised to drive for work on a specific date?
Do you store time-stamped documents (licence, insurance, NCT, tax where relevant) with expiry dates and reminders?
(This is exactly where a compliance platform like DriverFocus PERMIT can help - centralised records, expiry workflows, exceptions reporting and audit trail.)
B) Policy: is your standard unambiguous?
Does your Driving for Work policy explicitly define grey fleet and the rules for authorisation?
Does it require proof of:
valid insurance including business use
vehicle roadworthiness (e.g. NCT where applicable)
driver licence validity
Does it clearly state that driving for work is conditional on meeting these requirements?
The RSA/HSA guidance stresses clear policies as a foundation of risk management.
C) Supervision: who checks, how often and what happens when it fails?
What is your re-check cadence (e.g. insurance renewal dates, annual checks, trigger-based checks)?
Who follows up on missing/expired documents - and what escalation exists?
Do managers know they are accountable for allowing/assigning work travel only to authorised drivers?
The HSA’s grey fleet materials emphasise managing grey fleet within your safety management system - not as an informal admin task.
D) Data integrity: is reimbursement creating a hidden liability?
Are you paying mileage without verifying the driver/vehicle was compliant at the time?
Can you reconcile:
expense claims
trip purpose
authorised driver status
insured vehicle status (including business class of use)
If you can’t, you may be building an audit problem while thinking you’re running a payroll process.
What “good” looks like in practice
For medium to large Irish employers, a sensible operating model is:
Eligibility gate: no driving-for-work authorisation without verified insurance (including business use), licence and vehicle compliance.
Expiry automation: reminders before renewal dates; blocked status after expiry.
Exception handling: managers alerted when a driver is non-compliant; alternative travel arrangements required.
Audit-ready reporting: at any point, you can evidence who was eligible, what was checked, and when.
This is also the direction of travel in national messaging: driving for work is a significant safety challenge and requires structured management.
A final director-level prompt
MIBI’s latest figures (reported February 2026) are not just a policing statistic - they’re a signal that uninsured driving is being detected at scale.
In that environment, grey fleet becomes a governance issue, not a “fleet admin” issue.
If you’re responsible for governance, people risk, or operational resilience, set a short internal review:
System: where is your single source of truth for driver and vehicle eligibility?
Policy: does it explicitly require insurance including business use and do staff understand it?
Supervision: who checks, how often, and what happens when someone is non-compliant?
Data integrity: are you paying mileage without verifying eligibility at the time of travel?
Sources
MIBI - 16th February 2026 - https://www.rte.ie/news/ireland/2026/0216/1558664-uninsured-vehicles
RSA Driving for Work Guidance (2025), p.16: Annual licence and fitness checks are essential.
Services:
PERMIT - online driving licence and insurance verification
SURVEY - online driver risk assessment
DRIVEALERT - online defensive driver training
DRIVESAFE - ADI-led interactive webinar courses
ALLY - mobile and web app for business mileage
Contact us today and see how our services can help you stay compliant and build a better culture of care.