A customer buys a car, three weeks pass and the vehicle is still registered in the dealership’s name in the DGT records. The buyer calls, the dealer does not respond quickly, and the customer decides to file a complaint. Or the other way round: the dealer sold the car, did not notify the sale in time, and fines start arriving in its name for offences committed by the new owner.
Professional vehicle sales businesses have an ongoing relationship with the DGT that goes beyond filling in forms. Changes of ownership, sale notifications, ITV inspections, temporary deregistrations: each operation creates administrative obligations with specific deadlines. Failing to meet them not only leads to financial penalties, it also opens the door to customer complaints and ex officio inspections. Understanding properly what can go wrong, and why, is the best way to make sure it doesn’t.
Contents
When a customer can report a dealership to the DGT
When the DGT acts of its own accord against a dealership
What penalties the DGT can impose
The DGT obligations that are most often breached in vehicle sales
How to respond to a DGT complaint or inspection
When a customer can report a dealership to the DGT
Most complaints that a customer files against a professional vehicle sales business stem from one of these three scenarios.
The change of ownership is not processed on time. After the sales contract is signed, the buyer is required to carry out the change of ownership within a maximum of 30 days. In practice, many dealerships handle this process on behalf of the customer or through an administrative agent, and when there are delays or mistakes in the process, the customer sees it as a breach by the dealer. If the vehicle is still in the dealership’s name after that period, the buyer can report the situation to the DGT and demand that it be resolved.
If you want to know how to speed up this process, we explain how digital change of ownership with the DGT works
The car is handed over with hidden encumbrances. A vehicle with an active reservation of title, an outstanding seizure order or unpaid fines cannot be transferred until those encumbrances have been cancelled. If the customer later discovers that the car had encumbrances that the dealership did not disclose, they can report it both to the DGT and to consumer protection bodies. This is one of the most common reasons for complaints and also one of the most avoidable: a check of the DGT report before putting the vehicle up for sale will detect it in seconds.
The vehicle is handed over without a valid ITV. Delivering a car with an expired ITV is a breach that the customer can report. In addition to the complaint, the dealership may face claims for the costs arising from passing the ITV or from being unable to drive the vehicle until it is done.
When the DGT acts of its own accord against a dealership
Beyond customer complaints, the DGT can act on its own initiative when it detects irregularities in a vehicle sales business’s activity.
Repeated failure to notify sales. Sale notification is mandatory when the transfer is not carried out jointly by buyer and seller. If a dealership that sells dozens of vehicles a year fails to notify sales systematically, it accumulates vehicles in its name that continue to circulate, generating fines and liabilities that should belong to the new owners. When the pattern is repeated, the DGT can begin an ex officio sanctioning procedure.
Irregularities in vehicle documentation. A chassis number that does not match the documentation, unregistered technical modifications or vehicles registered with incorrect data are situations that may be detected during inspections or routine procedures and lead to sanctioning proceedings.
Sale of vehicles that cannot be transferred. A vehicle with unpaid fines or with the previous year’s road tax outstanding cannot be transferred. If a dealership tries to process a transfer for a vehicle that does not meet the requirements, the DGT blocks the procedure and may investigate the operation.
What penalties the DGT can impose
The penalties a professional vehicle sales business may receive for breaches before the DGT vary depending on the seriousness of the offence.
In the case of a change of ownership filed out of time, fines usually range between €200 and €500 depending on the autonomous community. These are not astronomical amounts, but if the delay is common in the business and affects several vehicles a month, the total quickly becomes significant.
More costly is the scenario in which the dealership is still listed as the owner of vehicles it has already sold and has not notified. Until the change of ownership is recorded in the Vehicle Register, fines from fixed cameras, insurance or ITV will continue to be sent in the seller’s name. Each offence committed by the new owner who is not registered as the keeper becomes an administrative and financial problem for the dealership.
In the most serious cases, when there is forgery of documents or tampering with the chassis number, the consequences go beyond the financial penalty: the vehicle may be immobilised and the matter is treated as a criminal offence, with the need to prove in court that the anomalies are the responsibility of the previous owner.
The DGT obligations that are most often breached in vehicle sales
Knowing where the usual risk points are helps avoid them before they create problems.
Sale notification after each transaction. This is the most common breach. Many dealers assume that the customer will handle the change of ownership and do not notify the sale themselves. The problem is that if the buyer is slow to complete the transfer, fines from fixed cameras and for not having passed the ITV will continue to go to the seller until the change of ownership or the sale notification is made. Notifying the sale of a vehicle to the DGT is a procedure that can be done immediately after the contract is signed and removes any subsequent liability from the dealership.
Checking that the vehicle can be transferred before selling it. Before closing a deal, you need to confirm that the car is registered as active, that the previous year’s road tax has been paid, that it has no recorded encumbrances and that there are no sanctions blocking the transfer. Skipping this step is the main cause of problems when it comes to processing the change of ownership. From Dealcar you can check the DGT report directly from each vehicle record, without leaving the platform, which makes this verification a natural part of the workflow rather than an extra task.
Proper management of temporary deregistrations. Stock vehicles that will not be driven for a period can be temporarily deregistered to reduce costs. But temporary deregistration has its own obligations: if the vehicle is under temporary deregistration, the owner must register it again before carrying out the transfer. A car under temporary deregistration that is sold without first arranging the re-registration blocks the procedure and creates delays that the customer ends up paying for with their patience.
If you want to understand this process properly, we explain the full procedure in our guide to temporary vehicle deregistration: process, advantages and considerations.
Valid ITV at the time of handover. Selling a car with an expired ITV is not only a legal problem for the buyer: it is a direct cause of claims and complaints. Keeping track of the ITV status of each vehicle in stock is a basic task that, with many cars on display, can easily be overlooked if it is not managed systematically.
If you want to go deeper into the specific obligations related to the ITV, you can find all the details in our article on ITV obligations for car dealerships.
How to respond to a DGT complaint or inspection
If you receive a complaint notice or a communication from the DGT about an irregularity, these are the steps you should follow.
Do not ignore the appeal period. Every administrative penalty includes a period for submitting representations, usually between 10 and 15 working days from notification. If you have documents proving that you met your obligations (signed contract, registered sale notification, DGT report obtained before the sale), this is the time to submit them. A well-documented representation can reduce or cancel the penalty.
Gather the transaction documentation. The sales contract signed by both parties, proof of the sale notification, the DGT report checked before the transaction and any communication with the customer are the evidence you need to defend your position. If you do not have any of them, now is the time to strengthen the process so it does not happen again.
Review which documents must not be missing in each transaction in our article on mandatory documentation for dealerships when selling.
Consider legal advice in serious cases. For minor penalties arising from administrative delays, direct representations are usually sufficient. When the complaint involves allegations of fraud, document forgery or serious irregularities, having a lawyer specialising in administrative or consumer law is the most sensible decision.
Set up a protocol to prevent it happening again. A complaint or penalty is a sign that a process is not working properly. Reviewing the workflow for each transaction, from purchasing the vehicle to handing it over to the customer, and identifying which step was skipped is more valuable than dealing with the penalty itself.
The relationship between a professional vehicle sales business and the DGT is not complex, but it does require order. Most of the complaints and penalties dealers receive originate in administrative oversights that build up as the business grows and processes do not scale with it. Being clear about which procedures are mandatory, within what deadline and with which documentation is the difference between operating smoothly and spending time and money solving problems that should never have happened.
Frequently asked questions
Can a customer report a dealership to the DGT for not carrying out the change of ownership?
Yes. If the dealership agreed to handle the change of ownership and did not do so within 30 days of the contract being signed, the customer can report it to the DGT and to consumer protection bodies. The 30-day deadline is mandatory by law and failing to meet it creates liabilities for whoever was supposed to handle it.
What happens if I sell a car and do not notify the sale to the DGT?
Until the sale notification or change of ownership is recorded, the dealership remains listed as the vehicle’s owner. Any fine, offence or ITV issue caused by the new owner will continue to be sent in the dealer’s name until the situation is regularised. Notifying the sale immediately after signing the contract is the simplest way to avoid this.
Can I sell a car with an expired ITV?
Technically the sale can be completed, but the vehicle cannot be driven with an expired ITV. Handing over a car in that condition to the customer is a direct cause of a claim and may lead to a complaint. The recommended approach is to pass the ITV before delivery or agree it expressly in the contract, making clear who bears the cost and handles the procedure.
What documentation do I need to respond to a DGT penalty?
The sales contract signed by both parties, proof of the sale notification registered with the DGT, the DGT report checked before the transaction and any written communication with the customer. The more documentation you have in order, the stronger your representations will be in the event of a penalty.
Can the DGT penalise a dealership for selling a car with hidden encumbrances?
The DGT can block the transfer if the vehicle has uncancelled encumbrances, which creates a direct conflict with the customer. If the dealership knew about the encumbrances and did not disclose them, liability may lead to a civil or consumer claim as well as administrative problems with the DGT. Checking the vehicle’s status before each sale is the only way to avoid this situation.
More than 500 vehicle sales businesses already use Dealcar to manage their day-to-day operations.
From checking the DGT report to generating contracts and monitoring the status of each vehicle in stock, everything is recorded in one place. If you want to see how it works, you can book a free demo at dealcar.io.
A customer buys a car, three weeks pass and the vehicle is still registered in the dealership’s name in the DGT records. The buyer calls, the dealer does not respond quickly, and the customer decides to file a complaint. Or the other way round: the dealer sold the car, did not notify the sale in time, and fines start arriving in its name for offences committed by the new owner.
Professional vehicle sales businesses have an ongoing relationship with the DGT that goes beyond filling in forms. Changes of ownership, sale notifications, ITV inspections, temporary deregistrations: each operation creates administrative obligations with specific deadlines. Failing to meet them not only leads to financial penalties, it also opens the door to customer complaints and ex officio inspections. Understanding properly what can go wrong, and why, is the best way to make sure it doesn’t.
Contents
When a customer can report a dealership to the DGT
When the DGT acts of its own accord against a dealership
What penalties the DGT can impose
The DGT obligations that are most often breached in vehicle sales
How to respond to a DGT complaint or inspection
When a customer can report a dealership to the DGT
Most complaints that a customer files against a professional vehicle sales business stem from one of these three scenarios.
The change of ownership is not processed on time. After the sales contract is signed, the buyer is required to carry out the change of ownership within a maximum of 30 days. In practice, many dealerships handle this process on behalf of the customer or through an administrative agent, and when there are delays or mistakes in the process, the customer sees it as a breach by the dealer. If the vehicle is still in the dealership’s name after that period, the buyer can report the situation to the DGT and demand that it be resolved.
If you want to know how to speed up this process, we explain how digital change of ownership with the DGT works
The car is handed over with hidden encumbrances. A vehicle with an active reservation of title, an outstanding seizure order or unpaid fines cannot be transferred until those encumbrances have been cancelled. If the customer later discovers that the car had encumbrances that the dealership did not disclose, they can report it both to the DGT and to consumer protection bodies. This is one of the most common reasons for complaints and also one of the most avoidable: a check of the DGT report before putting the vehicle up for sale will detect it in seconds.
The vehicle is handed over without a valid ITV. Delivering a car with an expired ITV is a breach that the customer can report. In addition to the complaint, the dealership may face claims for the costs arising from passing the ITV or from being unable to drive the vehicle until it is done.
When the DGT acts of its own accord against a dealership
Beyond customer complaints, the DGT can act on its own initiative when it detects irregularities in a vehicle sales business’s activity.
Repeated failure to notify sales. Sale notification is mandatory when the transfer is not carried out jointly by buyer and seller. If a dealership that sells dozens of vehicles a year fails to notify sales systematically, it accumulates vehicles in its name that continue to circulate, generating fines and liabilities that should belong to the new owners. When the pattern is repeated, the DGT can begin an ex officio sanctioning procedure.
Irregularities in vehicle documentation. A chassis number that does not match the documentation, unregistered technical modifications or vehicles registered with incorrect data are situations that may be detected during inspections or routine procedures and lead to sanctioning proceedings.
Sale of vehicles that cannot be transferred. A vehicle with unpaid fines or with the previous year’s road tax outstanding cannot be transferred. If a dealership tries to process a transfer for a vehicle that does not meet the requirements, the DGT blocks the procedure and may investigate the operation.
What penalties the DGT can impose
The penalties a professional vehicle sales business may receive for breaches before the DGT vary depending on the seriousness of the offence.
In the case of a change of ownership filed out of time, fines usually range between €200 and €500 depending on the autonomous community. These are not astronomical amounts, but if the delay is common in the business and affects several vehicles a month, the total quickly becomes significant.
More costly is the scenario in which the dealership is still listed as the owner of vehicles it has already sold and has not notified. Until the change of ownership is recorded in the Vehicle Register, fines from fixed cameras, insurance or ITV will continue to be sent in the seller’s name. Each offence committed by the new owner who is not registered as the keeper becomes an administrative and financial problem for the dealership.
In the most serious cases, when there is forgery of documents or tampering with the chassis number, the consequences go beyond the financial penalty: the vehicle may be immobilised and the matter is treated as a criminal offence, with the need to prove in court that the anomalies are the responsibility of the previous owner.
The DGT obligations that are most often breached in vehicle sales
Knowing where the usual risk points are helps avoid them before they create problems.
Sale notification after each transaction. This is the most common breach. Many dealers assume that the customer will handle the change of ownership and do not notify the sale themselves. The problem is that if the buyer is slow to complete the transfer, fines from fixed cameras and for not having passed the ITV will continue to go to the seller until the change of ownership or the sale notification is made. Notifying the sale of a vehicle to the DGT is a procedure that can be done immediately after the contract is signed and removes any subsequent liability from the dealership.
Checking that the vehicle can be transferred before selling it. Before closing a deal, you need to confirm that the car is registered as active, that the previous year’s road tax has been paid, that it has no recorded encumbrances and that there are no sanctions blocking the transfer. Skipping this step is the main cause of problems when it comes to processing the change of ownership. From Dealcar you can check the DGT report directly from each vehicle record, without leaving the platform, which makes this verification a natural part of the workflow rather than an extra task.
Proper management of temporary deregistrations. Stock vehicles that will not be driven for a period can be temporarily deregistered to reduce costs. But temporary deregistration has its own obligations: if the vehicle is under temporary deregistration, the owner must register it again before carrying out the transfer. A car under temporary deregistration that is sold without first arranging the re-registration blocks the procedure and creates delays that the customer ends up paying for with their patience.
If you want to understand this process properly, we explain the full procedure in our guide to temporary vehicle deregistration: process, advantages and considerations.
Valid ITV at the time of handover. Selling a car with an expired ITV is not only a legal problem for the buyer: it is a direct cause of claims and complaints. Keeping track of the ITV status of each vehicle in stock is a basic task that, with many cars on display, can easily be overlooked if it is not managed systematically.
If you want to go deeper into the specific obligations related to the ITV, you can find all the details in our article on ITV obligations for car dealerships.
How to respond to a DGT complaint or inspection
If you receive a complaint notice or a communication from the DGT about an irregularity, these are the steps you should follow.
Do not ignore the appeal period. Every administrative penalty includes a period for submitting representations, usually between 10 and 15 working days from notification. If you have documents proving that you met your obligations (signed contract, registered sale notification, DGT report obtained before the sale), this is the time to submit them. A well-documented representation can reduce or cancel the penalty.
Gather the transaction documentation. The sales contract signed by both parties, proof of the sale notification, the DGT report checked before the transaction and any communication with the customer are the evidence you need to defend your position. If you do not have any of them, now is the time to strengthen the process so it does not happen again.
Review which documents must not be missing in each transaction in our article on mandatory documentation for dealerships when selling.
Consider legal advice in serious cases. For minor penalties arising from administrative delays, direct representations are usually sufficient. When the complaint involves allegations of fraud, document forgery or serious irregularities, having a lawyer specialising in administrative or consumer law is the most sensible decision.
Set up a protocol to prevent it happening again. A complaint or penalty is a sign that a process is not working properly. Reviewing the workflow for each transaction, from purchasing the vehicle to handing it over to the customer, and identifying which step was skipped is more valuable than dealing with the penalty itself.
The relationship between a professional vehicle sales business and the DGT is not complex, but it does require order. Most of the complaints and penalties dealers receive originate in administrative oversights that build up as the business grows and processes do not scale with it. Being clear about which procedures are mandatory, within what deadline and with which documentation is the difference between operating smoothly and spending time and money solving problems that should never have happened.
Frequently asked questions
Can a customer report a dealership to the DGT for not carrying out the change of ownership?
Yes. If the dealership agreed to handle the change of ownership and did not do so within 30 days of the contract being signed, the customer can report it to the DGT and to consumer protection bodies. The 30-day deadline is mandatory by law and failing to meet it creates liabilities for whoever was supposed to handle it.
What happens if I sell a car and do not notify the sale to the DGT?
Until the sale notification or change of ownership is recorded, the dealership remains listed as the vehicle’s owner. Any fine, offence or ITV issue caused by the new owner will continue to be sent in the dealer’s name until the situation is regularised. Notifying the sale immediately after signing the contract is the simplest way to avoid this.
Can I sell a car with an expired ITV?
Technically the sale can be completed, but the vehicle cannot be driven with an expired ITV. Handing over a car in that condition to the customer is a direct cause of a claim and may lead to a complaint. The recommended approach is to pass the ITV before delivery or agree it expressly in the contract, making clear who bears the cost and handles the procedure.
What documentation do I need to respond to a DGT penalty?
The sales contract signed by both parties, proof of the sale notification registered with the DGT, the DGT report checked before the transaction and any written communication with the customer. The more documentation you have in order, the stronger your representations will be in the event of a penalty.
Can the DGT penalise a dealership for selling a car with hidden encumbrances?
The DGT can block the transfer if the vehicle has uncancelled encumbrances, which creates a direct conflict with the customer. If the dealership knew about the encumbrances and did not disclose them, liability may lead to a civil or consumer claim as well as administrative problems with the DGT. Checking the vehicle’s status before each sale is the only way to avoid this situation.
More than 500 vehicle sales businesses already use Dealcar to manage their day-to-day operations.
From checking the DGT report to generating contracts and monitoring the status of each vehicle in stock, everything is recorded in one place. If you want to see how it works, you can book a free demo at dealcar.io.
