below a email received from the Border Force, this clarifies the situation for accredited hauliers.
Currently, while a company remains accredited we accept that a company has an effective system and will not receive a penalty. If their driver has not operated their system they can still receive a fine (or face criminal prosecution if evidence suggests involvement) A company is severally liable for the drivers penalty so this could still fall to the company.
Checklists are accepted as a record of checks, photos would be additional evidence of a well operated system.
We ask that a driver operate the company’s system, if they have secure their vehicle, carry out and record their checks they should not receive a penalty – many such cases are not referred for Civil Penalty action but each case is reviewed separately.
There are nine Dutch hauliers accredited currently.
Ignored? I can’t imagine that possible.
Clandestine Entrant Civil Penalty Team (CECPT) – https://www.gov.uk/secure-your-vehicle-to-help-stop-illegal-immigration
Border Force South East and Europe