CACES and authorisation for a road-rail vehicle

Overview

Reading the operator file at four levels

The first level is training in safe operation, suited to the equipment and its operating conditions. The second may be a CACES: this scheme is a recognised means of assessing knowledge and skills within the category covered. The third is the authorisation to operate, a decision issued by the head of the establishment under the applicable framework. The fourth brings together the rail, network, site and job-specific rules linked to the tasks actually assigned.

These four levels have different purposes. A valid CACES is not the employer's authorisation to operate. An authorisation to operate does not automatically qualify its holder for a critical rail safety task. None of these documents alone grants the right to take any vehicle onto any track.

Item

WHO ISSUES IT?

What it does not replace

Training in safe operation

Employer or specialised training body depending on the organisation

Assessment and the decision to authorise

Caces

Testing body certified for the scheme concerned

Authorisation issued by the head of the establishment

Authorisation to operate

Head of establishment, based on the required elements

Network admission and rail qualification

Rail competency record

Relevant organisation under its safety management system

Employer's authorisation for the work equipment

Labour law

Applying the ministerial order of 26 September 2025 to the real situation

The ministerial order of 26 September 2025 (arrêté du 26 septembre 2025) governs training in operating self-propelled mobile work equipment and lifting equipment. Its article 2 provides for an authorisation to operate for certain families, including remote-controlled or ride-on construction equipment and mobile elevating work platforms. The equipment must be qualified by its function and by the text, not merely by its nickname within the fleet.

Article 3 provides that the authorisation is drawn up and issued by the head of the establishment based on an assessment comprising three elements: a valid medical certificate of no contraindication, a check of knowledge and skills for safe operation, and knowledge of the layout and instructions to follow at the site(s) of use. The CACES can contribute to the second element, but does not on its own cover the other two.

Working checklist

• ✓ Qualify the equipment and check whether an authorisation to operate is required.
• ✓ Check the validity of the relevant medical certificate.
• ✓ Assess knowledge and skills for the category and configuration concerned.
• ✓ Train the employee on the layout, risks, traffic and instructions of the sites of use.
• ✓ Define in writing the scope of the authorisation and its review conditions.

CACES is not the employer's authorisation

Even where the CACES is suitable and valid, the head of the establishment must have all the elements required by the ministerial order before issuing the authorisation to operate.

CACES R.482

Checking category B3 and the certificate's limits

CACES recommendation R.482 places road-rail vehicles with sequential displacement in category B3, with road-rail hydraulic excavators given as an example. This indication helps structure a file for machines that genuinely fall within this category. It does not allow every piece of road-rail equipment to be filed under the same certificate: a MEWP, a vehicle or specialised equipment may fall under a different analysis.

• Compare the exact designation of the machine with the category shown on the certificate.
• Do not extend category B3 to any equipment capable of running on rail.
• Document the accessories, controls, limits and specific conditions of the machine.

Rail safety

Separating the authorisation to operate from critical tasks since April 2026

Since 1 April 2026, the ministerial order of 24 March 2026 (arrêté du 24 mars 2026) replaced the former 2015 TES framework with the framework for critical tasks for rail safety other than train driving. The list and the competencies required depend on the regulatory scope and the organisation's safety management system. Operating or driving a vehicle is not, without a task analysis, sufficient on its own to conclude that a person falls under each of these requirements.

Where they apply, the relevant training is confirmed by a training certificate and competencies are assessed and then recorded in an individual competency record. This file cannot be replaced by a CACES R.482 or by the authorisation to operate. Conversely, a rail qualification does not exempt the employer from its obligations relating to the work equipment.

The former TES label is no longer sufficient

Legacy files must be reviewed against the texts in force since 1 April 2026. Renaming them without analysing tasks, training and assessments does not amount to a substantive update.

Management

Tracking authorisations as decisions, not attachments

Trackary can centralise certificates, attestations, authorisations and competency records, then flag their deadlines. It can also trace which document was presented for a job. It does not decide on fitness, does not issue any authorisation and does not guarantee that a person is qualified for a vehicle, a task or a site.

• 1. Check the elements: verify identity, validity, category, assessments and site knowledge.
• 2. Decide the scope: have the competent authority formalise vehicles, sites, tasks and restrictions.
• 3. Publish the right version: make the authorisation in force accessible without deleting its history.
• 4. Review: trigger a review after a deadline, a change, an incident, an extended stoppage or a new vehicle.

Frequently asked questions

Sources and limits of this guide

• Légifrance — Ministerial order of 26 September 2025 (arrêté du 26 septembre 2025) ↗ Training and authorisation to operate the equipment concerned.
• Légifrance — Article 2 of the ministerial order of 26 September 2025 ↗ Categories requiring an authorisation to operate.
• Légifrance — Article 3 of the ministerial order of 26 September 2025 ↗ Assessment underlying the head of establishment's decision.
• INRS — Provisions relating to CACES ↗ Link between CACES, training and authorisation.
• Assurance Maladie — CACES recommendation R.482 ↗ Recommendation including the B3 road-rail category.
• Légifrance — Ministerial order of 24 March 2026 (arrêté du 24 mars 2026) ↗ Framework for critical rail safety tasks.
• CACES category, authorisation and competencies are determined according to the vehicle and the tasks.
• Recommendation R.482 and the consolidated texts must be consulted in the version applicable at the date of assessment.
• Trackary tracks records and deadlines; it does not assess an operator and issues no fitness determination or authorisation.