Who needs DWTS compliance? Phase 1 and Phase 2 explained

The Digital Waste Tracking Service (DWTS) does not apply to every waste business at the same time. The mandatory rollout is split into two distinct phases, determined entirely by your operational role and location within the UK.

Phase 1 begins 1 October 2026 (January 2027 in Scotland). This initial milestone applies directly to permitted waste receiving sites—any business holding an environmental permit or waste management licence that accepts waste on-site. This includes:

• Skip hire operators bringing loaded skips back to their own yards for sorting.
• Waste transfer stations handling municipal, commercial, or industrial waste.
• Materials recovery facilities (MRFs) and recycling centres.
• Landfill sites and treatment plants.

If your facility holds an environmental permit to accept waste from external carriers or producers, you are legally required to comply from the Phase 1 start date, regardless of your daily tonnage or business size.

Phase 2 is scheduled for October 2027. This stage expands the mandate to cover waste carriers, brokers, and dealers across the UK. If you transport, arrange, or trade waste but do not operate a permitted receiving yard, this is your deadline. Logistics and transport providers can, however, choose to onboard voluntarily during Phase 1 to test their workflows early.

Certain roles are currently excluded from mandatory reporting:

• Waste Producers: Businesses that simply generate waste do not fall under Phase 1 or Phase 2 rules. For now, producers must continue to satisfy their standard Duty of Care obligations under Section 34 of the Environmental Protection Act 1990, which includes completing standard Waste Transfer Notes (WTNs).
• Local Authorities: Council-run waste operations are currently unable to register or submit data under the Phase 1 service rules.

While the underlying central DWTS framework and reporting data points are identical across all four nations, implementation timelines vary slightly. England, Wales, and Northern Ireland go live on 1 October 2026, while Scottish sites have until January 2027 to complete their system testing and staff training.

For a comprehensive view of regulatory deadlines, read our guide to the DWTS deadline. To prepare your facility step-by-step, review our practical DWTS compliance checklist.