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What to avoid · 10 min read
The Direct Vision Standard and HGV-involved collisions in London: don't ignore the evidence position
What the Direct Vision Standard scheme is, the Progressive Safe System update, why HGV operators carry mandatory cameras, and how this changes the evidence position after a collision in Greater London.
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The Direct Vision Standard and HGV-involved collisions in London: don't ignore the evidence position
The Direct Vision Standard (DVS) is Transport for London's scheme that requires HGV operators to obtain a Safety Permit to drive HGVs over 12 tonnes in Greater London. Since the scheme launched on 1 March 2021 and was strengthened to the Progressive Safe System on 28 October 2024, every in-scope HGV operating in Greater London now carries cameras, sensors and warning equipment, and the operator carries a regulatory record. For non-fault drivers and cyclists involved in collisions with HGVs in London, this changes the evidence position substantially in the claimant's favour. This post explains how.
What the Direct Vision Standard actually is
The DVS measures how well an HGV driver can see directly through the cab windows without relying on cameras or mirrors. Each HGV is rated 0 to 5 stars depending on the cab design. Older flat-fronted cabs with small windows score 0 stars; modern low-cab designs with large glass areas score 4 or 5 stars. Permits are required for any HGV over 12 tonnes operating in Greater London.
Since 28 October 2024 under the Progressive Safe System, the minimum rating for a permit was raised from 1 star to 3 stars. HGVs with a lower rating must be retrofitted with the full Progressive Safe System equipment package - including a Class V mirror replacement, a side under-run protection bar, an audible left-turn alarm, side and front sensors with cab-mounted display, and external warning signage - before they can be operated in Greater London.
DETAIL
03
Section 3 of the walkthrough.
What the Progressive Safe System equipment captures
The Progressive Safe System equipment package includes both real-time blind-spot mitigation and recording functionality. The side and front sensors detect objects in the cab's blind spots; the cab-mounted display shows the driver what the sensors see; the audible alarm warns vulnerable road users when the HGV is turning; and many systems include camera recording that is retained on a circular buffer for around 14 to 30 days.
For a non-fault cyclist or pedestrian involved in a collision with an in-scope HGV in London, this means there is normally an internal recording of the moments leading up to the collision. The recording shows whether the driver acknowledged the warning, whether the equipment was working properly, and whether the manoeuvre was safe to make.
How the operator's record changes the evidence position
Operators of in-scope HGVs are required to maintain Safety Permit records and to demonstrate compliance with the equipment requirements. Where a collision has occurred, TfL's Direct Vision Standard team can verify whether the vehicle had a current permit at the time of the incident, what star rating the cab had, and whether the operator was in compliance with the Progressive Safe System.
Where the operator was not compliant - for example, the permit had expired, the equipment was not fitted, or the equipment was fitted but not maintained - that is admissible evidence of breach of duty in any subsequent civil claim. The breach of a regulatory standard supports the breach of the common law duty of care to other road users.
CLOCS - the construction logistics counterpart
Construction Logistics and Community Safety (CLOCS) is a sister standard for construction logistics in London. CLOCS-accredited operators commit to specified safety standards beyond the legal minimum, including driver training, vehicle equipment and journey management. Most major construction sites in London require CLOCS accreditation for HGVs entering and leaving the site.
Where the at-fault HGV was operating to or from a major construction site, the CLOCS framework adds an additional layer of records: the operator's CLOCS-compliant journey plan, the driver training records, the equipment maintenance records, and the site's own access controls. Each of these is potentially admissible in a contested liability case.
06DETAILKey takeaway
Practical evidence steps for a non-fault driver or cyclist
Within the first 24 hours: report to the police and obtain the CAD reference; note the HGV's registration, the operator's name and any livery; lodge a disclosure request with TfL's Direct Vision Standard team for the permit status; lodge a disclosure request with the operator for the in-vehicle camera recording.
Within 72 hours: lodge CCTV requests with the relevant London borough council and with TfL for any traffic-management cameras at the location; identify any bus that was passing at the time and request the bus-cam footage from TfL; note the construction site if any HGV deliveries were associated. Within 7 days: confirm the operator's CLOCS status if applicable; identify whether the police investigation involves DVSA on the HGV side.
Why this matters for liability arguments
Cyclist and pedestrian fatality cases involving HGVs were historically among the most contentious liability cases in London, because the HGV driver often had a defensible 'I didn't see them' argument due to genuine cab blind spots. Direct Vision Standard substantially closes that defence. A driver of a 3-star or higher cab in 2026 cannot easily say they did not see a cyclist directly to the side of the cab; the Class V mirror, the side sensor and the audible alarm together remove most of the historical blind-spot argument.
From the at-fault insurer's perspective, defending the HGV driver in a 2026 collision in London is structurally harder than it was a decade ago. From the non-fault claimant's perspective, the regulatory evidence package supplements the standard photographic and CCTV evidence and produces a strong liability position.
What about HGVs operating outside Greater London?
DVS is a Greater London scheme. Outside London, no equivalent regulatory requirement applies, and HGV operators are subject only to general roadworthiness, Construction and Use Regulations and DVSA enforcement. The evidence package for an HGV-involved collision outside London is therefore narrower; primary reliance is on the operator's voluntary equipment, the police investigation and the standard CCTV/dashcam evidence.
Several other UK cities are considering similar schemes; Birmingham and Manchester have looked at HGV safety schemes in different forms. For now, DVS is unique to London and shifts the evidence balance for collisions inside the M25.
DETAIL
09
Section 9 of the walkthrough.
Personal injury cases - the priority of consent and consent-only referral
HGV-involved collisions involving cyclist or pedestrian injury are normally referred to specialist personal injury solicitors with experience of the regulatory regime. CityGrip Accident Claims does not handle injury claims in-house; injury enquiries are referred only with the claimant's separate written consent to authorised legal or regulated partners.
The consent-only referral model is important because UK GDPR Article 7 and the FCA's marketing rules require data sharing for injury referral to be a separate, opt-in choice. Bundling injury referral consent into a property damage claim is unlawful under the data protection framework. Genuine accident management firms keep the consents separate; the offered referral does not happen unless the claimant separately agrees.
Take action
If you have just been in a non-fault collision, the fastest way to protect your claim is to open the file with us inside the first hour. We dispatch recovery, lodge the relevant CCTV requests inside the retention window, and notify the third-party insurer for you.
We do not provide legal advice. This article is general guidance for UK drivers. Personal injury enquiries are referred only with your consent to authorised legal or regulated partners. Specific limits, retention windows and process steps may change; the position at the date of any individual collision will govern the handling of that claim.
Frequently asked questions
- What is the Direct Vision Standard star rating?
- A 0-5 star rating of how well the HGV driver can see directly through the cab windows. 5 stars is best; 0 stars requires the full Progressive Safe System retrofit since 28 October 2024.
- Does DVS apply to all HGVs?
- It applies to HGVs over 12 tonnes operating in Greater London. Lighter vehicles and HGVs operating outside London are not in scope.
- Where do I get the operator's camera recording?
- The operator's claims or operations team. The data subject access request under UK GDPR Article 15 is available to people whose personal data was recorded.
- What is CLOCS?
- Construction Logistics and Community Safety - a voluntary scheme operated by the construction industry that adds safety standards beyond DVS for HGVs operating to and from major construction sites.
- How long does TfL keep DVS permit records?
- The permit record is administrative and is retained while the permit is current and for a period after expiry. Compliance status at the date of any incident can be confirmed on request.
- Will my injury claim be handled by you?
- No. We do not handle personal injury claims in-house. With your separate written consent we refer to authorised specialist personal injury solicitors who handle HGV-involved cases.
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