The new TVDE sticker: non-removable, anti-fraud and with a QR code

The short answer

Under the new law, TVDE cars will carry a non-removable sticker, issued by the IMT, Portugal’s transport authority, with anti-fraud security features and a QR code that allows anyone to confirm the vehicle is authorised. The rule is in article 12, paragraphs 10, 13, 14 and 15, of the revised regime. The actual design, technical features and fee are left to an implementing regulation which, at the time of writing, has not yet been published. Until then, there is no new sticker to display.

What the law says about the new sticker

Paragraph 10 of article 12 defines the essentials. Vehicles assigned to the activity carry a "non-removable identification sticker, with anti-fraud security features, namely holographic or technologically equivalent, issued by the IMT, IP, visible from outside and linked to the vehicle registration". There are five features, each with its own purpose:

• non-removable: it cannot be moved from car to car, as happened with the 2018 sticker;
• anti-fraud: holograms or equivalent technology, to make forgery harder;
• issued by the IMT: only the IMT issues it, not the operator or the platform;
• visible from outside: for passengers and inspectors;
• linked to the vehicle registration: paragraph 2 of the same article says the number issued with the vehicle registration with the IMT is shown on the sticker.

The QR code and the four items it reveals

Paragraph 13 adds a digital identifier, "accessible through a two-dimensional barcode (QR code) or other equivalent means of electronic reading", which makes it possible to validate the vehicle registration with the IMT. Anyone with a mobile phone should, in principle, be able to point the camera at the sticker and confirm whether that car can do TVDE.

Paragraph 14 limits what that scan shows the public. The information "is limited to confirming" four items:

1. vehicle authorised for the TVDE activity;
2. the vehicle’s number plate;
3. the TVDE operator licence number;
4. the existence of valid insurance for the TVDE activity.

Note what is left out: the driver’s name, the owner’s details, the company address. The driver is still identified in the app, which must show their unique registration number and photo (article 19, paragraph 1, subparagraph e)). The sticker is there to confirm the car, not to expose people.

For passengers, the most useful check is the number plate. If the car that pulled up does not have the plate shown in the app, or if scanning the QR code does not confirm the authorisation, it is a warning sign. For those working, the valid insurance confirmation has a direct consequence: an expired policy becomes visible to anyone who scans the code.

What changed from the 2018 sticker

In the original version of Law no. 45/2018, article 12, paragraph 7, said vehicles operated "without any external sign indicating the type of service they provide, except for a sticker, visible from outside and removable, on terms to be defined by decision of the IMT board of directors". The law required no security features and no link to any registration, not least because in 2018 vehicles had no registration of their own with the IMT: it was enough for them to be listed on the platform.

The removable sticker had a practical advantage, moving from car to car, which was also its weakness: a sticker that peels off and sticks back on does not, in itself, prove that a specific car meets the requirements. The new law responds with three layers: the sticker no longer comes off the glass, it is tied to the registration of that specific vehicle and it can now be checked electronically.

Another fundamental difference: defining the design moves from the IMT board of directors to an implementing regulation by the government member responsible for mobility, which also sets the fee. And the phrase "without any external sign" has disappeared from article 12, which now allows advertising inside or outside the vehicle, on the terms laid down for taxis (paragraph 11).

What the implementing regulation still has to define

Paragraph 15 leaves to an implementing regulation "the design, technical features, security features, conditions for issuing, replacing, cancelling and validating, as well as the fee due for the identification sticker". In other words, the law does not answer practical questions such as:

• where the sticker is placed and at what size;
• how much it costs;
• what happens when the car is sold or leaves the activity;
• how a damaged sticker is replaced, for example when the windscreen is changed;
• how the sticker is cancelled when the registration expires.

On these points, any answer before the implementing regulation is speculation. The list of missing regulations is in regulations yet to be published.

Fines and who is liable

Article 25, paragraph 2, subparagraph o), makes it an administrative offence to breach "the rules on displaying, issuing, using, replacing, cancelling or validating the identification sticker", under paragraphs 10 and 13 to 15 of article 12. The fine ranges from 250 to 4,500 euros for individuals and from 5,000 to 44,000 euros for companies, and attempt and negligence are punishable.

This offence may be charged to the driver, the operator and the platform manager, where the act is attributable to them (article 25-B, paragraphs 1, 2 and 3). The IMT handles the proceedings (article 25-A, paragraph 1, subparagraph a)). More detail ininspections and fines.

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