Phase 1 puts permitted waste receiving sites in scope from October 2026. Phase 2 brings in carriers, brokers and dealers, expected Autumn 2027. If you are in the second group it is tempting to file this under next year's problem.
The reason not to is that the hard part of Phase 2 is not the submission. It is having data clean enough to submit.
The real problem is where your data lives
Receiving sites usually have one system, because the weighbridge forces the issue. Carriers and brokers frequently do not. Jobs get booked in one place, drivers record collections in another or on paper, and the office reconciles it afterwards in a spreadsheet.
That works commercially. It does not survive a requirement to report every movement accurately and promptly, because there is no single point where a movement is definitively recorded.
Four things worth doing in the next twelve months
- Find the single source of truth, or create one. One place where a movement exists. Everything else can read from it. Without this, no amount of software helps.
- Get the driver's record into it directly. Anything a driver writes down and someone else types up will be your weakest link. A phone in the cab recording the collection at the point it happens removes a whole category of error.
- Tighten your waste descriptions now. Free-text descriptions are the thing that will fail validation at scale. Moving to a controlled list is boring work that takes months and is far easier before a deadline than during one.
- Check who you hand off to. Your movements have another end. If the receiving site is already reporting from October 2026 and their record of your load does not match yours, that mismatch is visible.
The quiet advantage
That last point is worth sitting with. From October 2026, sites you deliver into are reporting what they received. A year later you will be reporting what you carried. Those two records describe the same movement.
Carriers whose paperwork is already tight will find Phase 2 mostly administrative. Carriers who have been rounding will find it uncomfortable, and they will find it uncomfortable in public.
What not to do
Do not buy Phase 2 software now. The specification will move between phases and anything bought eighteen months early will need reworking anyway. Spend the time on your data instead. It is the part that transfers no matter what you eventually submit with.
Carrier or broker wanting a head start? A short call about where your movement data lives now is usually enough to tell you whether Phase 2 is an afternoon or a project. Book a call