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law TVDE 2026

practical guide

Setting up and running a TVDE operator

The operator is the central piece of the system: it is the entity responsible for the vehicles and the drivers. Setting one up requires registration, good standing and an IMT licence. Under the new law, obligations on fleet, data and heavier penalties are added. This guide sets out the path.

What an operator is

The law distinguishes two figures: the TVDE operator, responsible for the vehicles and the drivers, and the electronic platform manager, the company that owns the app, such as Uber or Bolt. A driver always works through an operator. Setting up an operator is therefore setting up the structure that employs or integrates drivers and assigns vehicles to the activity, then linking up with the platforms to capture trips.

How it is set up today

1. Company registered in Portugal

The operator must be a company registered in Portugal, and may also be a sole trader (empresário em nome individual). It is the first formal requirement: there must be a legal entity based in national territory.

2. Good standing of those in charge

All managers, administrators or directors must meet good standing requirements. It is a condition of access to the activity and is verified in the licensing process.

3. Operator licence from the IMT

The activity requires a TVDE operator licence, requested from the IMT through the Mod 30 IMT form (the IMT application form) or the online portal. There is also a separate licence for anyone who wants to be an electronic platform operator, a distinct figure. The vehicles assigned must meet the technical requirements of age, insurance, inspection and, under the new law, the badge.

What changes under the new law

The revision approved on 17 July 2026 tightens several rules for operators. The fleet must now be owned or on a formal lease or rental: comodato (free loan) and usufruct contracts for assigning vehicles to the activity become prohibited, save for exceptions. The aim is to end informal schemes for lending cars.

Operators will also share data with a national electronic platform run by the IMT, which cross-references information on operators, drivers, vehicles, insurance, inspections and licences, with access for the IMT, the AMT, the Tax Authority, Social Security and the security forces. Vehicles will have to display the identifying badge issued by the IMT. And penalties become heavier: fines for companies (legal persons) rise to 44,000 euros, up from the previous ceiling of 15,000 euros.

In the accounts with the platforms, the intermediation fee keeps its maximum of 25%, but now applies to the trip value excluding VAT, standardising practices that previously varied. It is a point to consider in the operator's financial planning.

Mistakes to avoid

Enforcement will tighten, and there are practices that no longer have room. Resorting to informal slots, putting cars in third parties' names to get around the fleet rules or using borrowed accounts are exactly the behaviours the new law wants to eliminate. Data sharing with the IMT platform makes these schemes easier to detect, and fines of up to 44,000 euros make the risk very high. Driving or operating with someone else's account is fraud and was already illegal before this revision.

flowchart TD
  A[company or sole trader] --> B[registered in Portugal]
  B --> C[good standing of the managers]
  C --> D[operator licence from the IMT]
  D --> E[owned fleet or formal lease and rental]
  E --> F[compliant vehicles with the IMT badge]
  F --> G[certified drivers registered]
  G --> H[data sharing with the IMT platform]
from setting up the company to operating with shared data

what you can do

  • set up the operator as a company registered in Portugal or a sole trader
  • request the operator licence from the IMT through the Mod 30 IMT form or online portal
  • assign owned vehicles or vehicles on a formal lease or rental, compliant with the technical requirements
  • integrate certified drivers and register the vehicles in the operator structure

what you cannot do

  • under the new law, assign vehicles through comodato or usufruct, save for exceptions
  • use informal slots, cars in third parties' names or borrowed accounts
  • operate without an IMT licence or with managers lacking good standing
  • ignore data sharing with the IMT platform, at the risk of fines of up to 44,000 euros

Practical cases

I want to set up a fleet with cars that partners lend me free of charge. Is it viable?

not allowed

Under the new law, no. Lending vehicles free of charge is a comodato, which becomes prohibited for assigning cars to the activity, save for exceptions. The fleet must be owned or on a formal lease or rental. You will have to structure the fleet through one of those admitted routes.

I am a sole trader. Can I be a TVDE operator?

allowed

Yes. The operator may be a company, but also a sole trader (empresário em nome individual), provided it is registered in Portugal, with good standing and an IMT licence. The vehicles assigned must meet the applicable technical requirements.

New rules depending on promulgation and government order

The tightened obligations for operators, the prohibition of comodato and usufruct, data sharing with the IMT platform, the badge and fines of up to 44,000 euros, were approved on 17 July 2026, but only apply after promulgation and publication in the official gazette (Diário da República), with technical aspects depending on a government order (portaria). Always confirm the framework in force with the IMT before investing.

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