Sounds like you’re familiar with the TM side of the job, using a phrase like Gap analysis 
We always do a SIPCAT for new clients, but as he hasn’t had any vehicles to run until a few days ago, there’s been nothing to analyse. You can be certain that we’ll be very actively managing his O-licence and telling exactly what he needs to do. He talks-the-talk about running compliantly, we’ll be on him all the time to make sure he walks-the-walk.
He’s been very fortunate to find people prepared to be patient with him, many others would have just walked away.