For permitted sites that use DutyOS to send waste receipts to DEFRA
Our DEFRA test results, and what you are responsible for
DEFRA publish 14 test scenarios, called production approval tests, that a software provider runs against DEFRA’s test service before asking for access to the live service. This page gives our own results, the gaps we know of in DutyOS, and what stays your responsibility when you use it.
These are our own results. The tests are a self-assessment by the software provider. DEFRA do not review, mark or approve test results. DEFRA issuing us with access to the live service is not confirmation by DEFRA that DutyOS is compliant.
Our results
Our test runner sent all 14 scenarios to DEFRA’s test service on 19 August 2026. Twelve were accepted. The other two, C01 and H02, are designed to be refused, and DEFRA’s test service refused both for the rule being tested, as expected. We claimed no exemption from any scenario.
On 20 October 2026 our test runner sent all 14 scenarios to DEFRA’s test service again. Every scenario behaved as DEFRA expect. The 12 accepting scenarios were accepted and given waste tracking IDs, and C01 and H02 were refused for the rule each one tests.
Since October 2026 DEFRA’s test service has offered a self service results check, which tells a provider whether each accepting scenario passes. We ran it straight after the 20 October run. All 12 accepting scenarios came back Pass. The check is automated, and it is not a review of DutyOS by DEFRA.
On 23 October 2026 we changed how a concentration is checked and entered, to take DEFRA’s new threshold sign (more than or less than a limit) on POPs and hazardous substances. We ran all 14 scenarios again the same day. The 12 accepting scenarios were accepted, C01 and H02 were refused for the rule each one tests, and DEFRA’s results check returned Pass for all 12.
On 31 October 2026, with the test credentials DEFRA issued on 28 October 2026, we ran all 14 scenarios again with no change to DutyOS. The 12 accepting scenarios were accepted, C01 and H02 were refused for the rule each one tests, and DEFRA’s results check returned Pass for all 12.
- R01 Accepted A receipt with a single waste item
- R02 Accepted A receipt with several waste items, each described separately
- R03 Accepted A receipt where the waste came by road
- R04 Accepted A receipt with no disposal or recovery code
- R05 Accepted A waste item with more than one disposal or recovery code
- R07 Accepted A waste item with more than one EWC code
- C01 Refused, as expected No carrier registration number, and no reason given
- C02 Accepted No carrier registration number, with a reason given
- B01 Accepted A broker or dealer involved in the movement
- P01 Accepted A waste item with more than one persistent organic pollutant (POPs)
- H01 Accepted A hazardous waste item with more than one hazardous substance
- H02 Refused, as expected Hazardous waste with no consignment note code, and no reason given
- H03 Accepted Hazardous waste with no consignment note code, with a reason given
- X01 Accepted A receipt with both hazardous and POPs details
| Scenario | What it tests | Expected outcome | Our result | Our last run |
|---|---|---|---|---|
| R01 | A receipt with a single waste item | Accepted, with a waste tracking ID | Accepted, the August 2026 failure is explained below | 31 October 2026 |
| R02 | A receipt with several waste items, each described separately | Accepted, with a waste tracking ID | Accepted | 31 October 2026 |
| R03 | A receipt where the waste came by road | Accepted, with a waste tracking ID | Accepted | 31 October 2026 |
| R04 | A receipt with no disposal or recovery code | Accepted, with a warning that the code is missing | Accepted | 31 October 2026 |
| R05 | A waste item with more than one disposal or recovery code | Accepted, with a waste tracking ID | Accepted | 31 October 2026 |
| R07 | A waste item with more than one EWC code | Accepted, with a waste tracking ID | Accepted | 31 October 2026 |
| C01 | No carrier registration number, and no reason given | Refused, with no waste tracking ID | Refused for the rule being tested, as expected | 31 October 2026 |
| C02 | No carrier registration number, with a reason given | Accepted, with a waste tracking ID | Accepted | 31 October 2026 |
| B01 | A broker or dealer involved in the movement | Accepted, with a waste tracking ID | Accepted | 31 October 2026 |
| P01 | A waste item with more than one persistent organic pollutant (POPs) | Accepted, with a waste tracking ID | Accepted | 31 October 2026 |
| H01 | A hazardous waste item with more than one hazardous substance | Accepted, with a waste tracking ID | Accepted, the August 2026 failure is explained below | 31 October 2026 |
| H02 | Hazardous waste with no consignment note code, and no reason given | Refused, with no waste tracking ID | Refused for the rule being tested, as expected | 31 October 2026 |
| H03 | Hazardous waste with no consignment note code, with a reason given | Accepted, with a waste tracking ID | Accepted | 31 October 2026 |
| X01 | A receipt with both hazardous and POPs details | Accepted, with a waste tracking ID | Accepted | 31 October 2026 |
Accepted means DEFRA’s test service took the receipt and gave it a waste tracking ID. DEFRA’s own wording for each scenario is on DEFRA’s production approval tests page.
R01 and H01 failed on 27 August 2026, and were run again
On 27 August 2026, under the manual review DEFRA used at the time, DEFRA marked R01 and H01 as failed. Both failures were in the content of our test receipts. Our R01 receipt had no disposal or recovery code, and our H01 receipt listed one hazardous substance where the scenario asks for more than one. We corrected the test receipts only, with no change to DutyOS itself, and ran both again on 27 August 2026. DEFRA’s test service accepted both with no warnings. We show the earlier failures because a failed result is still a failed result, whatever its cause.
How the tests were run
The test receipts were made up for the purpose. Our test runner built them and sent them with the same code that turns your receipts into DEFRA’s format and sends them. They were not typed into the receipt form, so these results show what DutyOS can carry to DEFRA, not what the receipt form lets you enter. The gaps in the form are listed below.
DEFRA’s API terms of service of 9 October 2026 ask providers to run the scenarios again after any release that could affect how receipt data is captured, validated or sent, and to keep a dated record of each run. That is why we ran all 14 again on 20 October 2026, on 23 October 2026 and on 31 October 2026, and we will keep doing so. The dates in the table are our most recent runs.
Known gaps in DutyOS
These are the gaps we know of, from comparing DutyOS with DEFRA’s published receipt specification. Weigh each one against the loads your site receives.
- Details the receipt form does not take. DEFRA’s specification marks these as optional. The receipt form has no box for them, so a receipt made on the form is sent without them: the carrier’s address, email address and phone number; your site’s email address, phone number and regulatory position statement numbers; special handling requirements; and references for the load other than your own reference.
- A broker or dealer’s address. The form takes a broker or dealer’s name, registration number, postcode, email address and phone number, but not the rest of the address. DEFRA’s guidance says Schedule 1 to the regulations asks for the name, address, contact details and registration or authorisation number of a broker or dealer who arranged the transport.
- Concentrations given as a limit. On the receipt form, the concentration of a persistent organic pollutant or a hazardous substance is a single figure in mg/kg. DEFRA’s specification also lets a receipt say that the concentration is below or above a figure. The form cannot record that, and DEFRA treat a figure sent on its own as the reported concentration.
- Code lists are copies. The pollutant codes and the container types the receipt form offers are DutyOS’s copies of DEFRA’s lists, read from DEFRA’s service on 20 October 2026: 31 pollutant codes and 16 container types. A code DEFRA adds after that date cannot be picked until DutyOS updates its copy. DEFRA publish no name for a pollutant code, only the code; the names shown beside the codes are ours, taken from Annex IV of the POPs Regulation, which DEFRA’s list follows. What is sent to DEFRA is always the code.
- Which nation a receipt belongs to. DutyOS works this out from the postcode of the site where the load was received, and uses it to decide when receipts can start to count as late: from 1 October 2026 in England and Wales, and from 1 January 2027 in Scotland. DutyOS treats 1 January 2027 in Northern Ireland as a target that is not yet law, and uses it there for this purpose only. A postcode DutyOS cannot place, or one in the TD area, which crosses the border between England and Scotland, is given the earlier date.
What you are responsible for
DEFRA’s terms for software providers ask us to make the following clear to every permitted site that uses DutyOS to meet regulation 4 of the Digital Waste Tracking (England) Regulations 2026 (S.I. 2026/729).
- You are responsible for your own due diligence when you choose software that captures and sends the specified information required by Schedule 1 to the regulations.
- You are responsible for satisfying yourself that DutyOS meets those requirements, including by reference to our self-certification test results on this page.
- DEFRA issuing production credentials to us is not confirmation by DEFRA that DutyOS is compliant, and you cannot rely on it as such.
- Responsibility for complying with regulation 4, and liability for any failure to do so, including under regulations 16 and 19 and Schedule 2 of the regulations, rests with you as the regulated operator. This is so regardless of any limitation, gap or defect in the software you have chosen to use, DutyOS included.
- We must tell you of any known limitation, gap or untested scenario in DutyOS clearly enough for you to make an informed decision about your own compliance. The ones we know of are set out above, under How the tests were run and Known gaps in DutyOS.
DEFRA’s terms refer to the England regulations. DEFRA’s guidance says that a site in Wales, Scotland or Northern Ireland should refer to the equivalent provisions in the regulations that apply in that nation.
Where to read more
- DEFRA’s Digital Waste Tracking API Terms of Service, last updated 9 October 2026.
- GOV.UK: Report receipt of waste: choose a software provider.
DutyOS is listed on GOV.UK’s list of software providers for the Report receipt of waste service. DEFRA’s terms say that being on that list is not a statement by DEFRA that a provider’s software complies with the regulations or has passed these tests.
If you need more detail on any result, email support@dutyos.co.uk. Page updated 31 October 2026.