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.

ScenarioWhat it testsExpected outcomeOur resultOur last run
R01A receipt with a single waste itemAccepted, with a waste tracking IDAccepted, the August 2026 failure is explained below31 October 2026
R02A receipt with several waste items, each described separatelyAccepted, with a waste tracking IDAccepted31 October 2026
R03A receipt where the waste came by roadAccepted, with a waste tracking IDAccepted31 October 2026
R04A receipt with no disposal or recovery codeAccepted, with a warning that the code is missingAccepted31 October 2026
R05A waste item with more than one disposal or recovery codeAccepted, with a waste tracking IDAccepted31 October 2026
R07A waste item with more than one EWC codeAccepted, with a waste tracking IDAccepted31 October 2026
C01No carrier registration number, and no reason givenRefused, with no waste tracking IDRefused for the rule being tested, as expected31 October 2026
C02No carrier registration number, with a reason givenAccepted, with a waste tracking IDAccepted31 October 2026
B01A broker or dealer involved in the movementAccepted, with a waste tracking IDAccepted31 October 2026
P01A waste item with more than one persistent organic pollutant (POPs)Accepted, with a waste tracking IDAccepted31 October 2026
H01A hazardous waste item with more than one hazardous substanceAccepted, with a waste tracking IDAccepted, the August 2026 failure is explained below31 October 2026
H02Hazardous waste with no consignment note code, and no reason givenRefused, with no waste tracking IDRefused for the rule being tested, as expected31 October 2026
H03Hazardous waste with no consignment note code, with a reason givenAccepted, with a waste tracking IDAccepted31 October 2026
X01A receipt with both hazardous and POPs detailsAccepted, with a waste tracking IDAccepted31 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.

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).

  1. 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.
  2. You are responsible for satisfying yourself that DutyOS meets those requirements, including by reference to our self-certification test results on this page.
  3. DEFRA issuing production credentials to us is not confirmation by DEFRA that DutyOS is compliant, and you cannot rely on it as such.
  4. 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.
  5. 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

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.