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Driving hours in TVDE: the 10-hour limit and who controls it

The ten-hours-a-day limit is not new, but the way it is controlled changed considerably in 2026. See what the law says, what it does not say and who is liable when the limit is exceeded.

The short answer

A TVDE driver may not operate TVDE vehicles for more than ten hours within a 24-hour period, adding up all the platforms they work on. If the applicable labour law sets a shorter limit, that one applies. The platform must have mechanisms that ensure the limit and must record working times. The ten-hour rule already existed in 2018; what is new in 2026 is the control: the ACT, Portugal’s labour inspectorate, now handles these offences and time recording becomes a condition for the platform to keep its licence.

The limit is in article 13, paragraph 1, of the TVDE regime: drivers "may not operate TVDE vehicles for more than ten hours within a 24-hour period, regardless of the number of platforms on which the TVDE driver provides services, without prejudice to the application of mandatory rules, namely the Labour Code, if they establish a shorter period".

The platforms add up

The expression "regardless of the number of platforms" closes the door on the obvious workaround of working ten hours on one app and a few more on another. The limit belongs to the driver, not to each platform. Six hours on one and five on another make eleven hours, and that breaks the law.

The practical problem is that each platform only sees its own hours. The 2026 law created the IMT’s data sharing platform (article 20-A), which platforms must join, and provides that the data to be shared with the tax authority (AT) and Social Security may include drivers’ "periods of activity" (paragraph 6). But the law does not expressly create a mechanism for cross-checking hours between platforms for the purposes of the ten-hour limit. In practice, whoever works on several apps is best placed to control the total, and is also the one liable for it.

What the law does not define

There are two questions that article 13 does not answer, and it is worth knowing them:

What "operate" means. The law does not say whether only time with a passenger counts, time on the way to a pickup, or all the time the driver is logged into the app and available for trips.
Which 24-hour period. The law does not say whether it is a calendar day, from midnight to midnight, or a rolling period counted from a given moment.

Without a legal definition, the actual criterion ends up being what each platform applies in its control mechanisms and what the ACT decides in its inspections. If you want a safety margin, count all the time you are logged in as activity time.

The platform’s role: control and record

The law places three obligations on the electronic platform manager:

Control mechanisms. Platform managers "must implement mechanisms that ensure compliance" with the limit (article 13, paragraph 2). This is why an app logs you out or stops you accepting trips after a certain time.
Time recording. The IT system must record the driver’s working times and compliance with driving and rest time limits (article 20, paragraph 3).
Keeping records. Platforms keep the activity records of operators, drivers and vehicles for two years, by unique driver registration number (article 13, paragraph 3).

All three already existed in 2018. What Law no. 59/2026 added was article 17-A, which defines the technological capacity required for the platform manager licence. Subparagraph b) of paragraph 2 includes "recording the driver’s working times and compliance with driving and rest time limits on its platform". Time recording is no longer just an operating duty and becomes a licensing requirement. Platforms have 120 days from the law’s entry into force to show they meet the technological capacity requirement (article 4, paragraph 1, of Law no. 59/2026).

The ACT takes over enforcement

In 2018, all administrative offences under the TVDE law were handled by the IMT (article 27 of the original law, now repealed). With the new article 25-A, responsibility is now shared, and the ACT takes three offences linked to working time:

subparagraph q): breach of the ten-hour limit in paragraph 1 of article 13;
subparagraph r): lack of mechanisms ensuring that limit, from paragraph 2 of article 13;
subparagraph y): breach of the duty to record working times and compliance with driving and rest limits, from paragraph 3 of article 20.

The ACT had been on the list of inspection bodies in article 24 since 2018. What is new is that it has its own power to handle these offences and impose the fines. The fines are the law’s general ones: from 250 to 4,500 euros for individuals and from 5,000 to 44,000 euros for companies, with attempt and negligence punishable and a possible additional penalty of a ban on the activity for up to two years.

As to who is liable, article 25-B charges subparagraph q) to the driver and the TVDE operator, where the act is attributable to them, and subparagraphs r) and y) to the platform manager. A curiosity: the 2018 law had a separate subparagraph for failing to keep the records in paragraph 3 of article 13, and the current list in article 25 does not repeat that reference.

Hours of activity: 2018 and 2026

topic	2018 law	new law
Daily limit	10 hours in 24, adding up platforms	Same, text unchanged
Control mechanisms	Obligation of platform operators	Obligation of platform managers (same entity, new name)
Time recording	Duty of the IT system (art. 20, para. 3)	Kept, and becomes a licence requirement (art. 17-A)
Who handles the offences	IMT	ACT
Fine, individual	2,000 to 4,500 euros	250 to 4,500 euros
Fine, company	5,000 to 15,000 euros	5,000 to 44,000 euros

The working time rules the law refers to

The ten hours are a ceiling set by the TVDE law, not the only possible limit. Article 13 itself preserves mandatory rules that set a shorter period, giving the Labour Code as an example. And article 10, paragraph 18, requires the following to apply, without prejudice to other legislation:

for drivers bound by an employment contract, the working time rules for people performing mobile road transport activities, in Decree-Law no. 237/2007 of 19 June;
for self-employed drivers, the working time rules in Decree-Law no. 117/2012 of 5 June.

This provision also already existed in 2018, in paragraph 12 of article 10. The TVDE law does not reproduce the limits in those laws, so the rules on breaks, daily and weekly rest or night work have to be looked up there, not in the TVDE regime. Whether you are an employee or self-employed is therefore also relevant to working time. See the article on thecontract between driver and operator.

I do 7 hours on one app and then 4 on another, on the same day

not allowed

That is 11 hours within 24, above the ten-hour limit. Article 13, paragraph 1, adds up the hours on all platforms. The offence is chargeable to the driver and the operator, where the act is attributable to them, and is handled by the ACT.

I am employed by the operator, on an 8-hour schedule

it depends

The ten-hour limit in the TVDE law is a maximum. If the labour rules that apply to you, including Decree-Law no. 237/2007 and the Labour Code, set a shorter period, that one prevails. The ten hours do not allow you to exceed the limits of your contract and of labour law.

Frequently asked questions

How many hours can a TVDE driver work per day?

The TVDE law says drivers may not operate TVDE vehicles for more than ten hours within a 24-hour period (article 13, paragraph 1). If a mandatory rule, such as the Labour Code, sets a shorter period, that shorter limit prevails.

If I work on two platforms, do the hours add up?

Yes. The limit applies "regardless of the number of platforms on which the TVDE driver provides services". Six hours on one app and five on another make eleven hours, above the limit.

Who is fined for going over 10 hours: the driver or the platform?

Breaching the 10-hour limit (subparagraph q) of paragraph 2 of article 25) is chargeable to the driver and to the TVDE operator, where the act is attributable to them. The lack of control mechanisms (subparagraph r)) and breach of the duty to record times (subparagraph y)) are chargeable to the platform manager.

Who enforces driving hours in TVDE?

Handling the administrative offences relating to the hours limit, the control mechanisms and time recording falls to the Working Conditions Authority, the ACT (article 25-A, paragraph 1, subparagraph c)). Other inspection bodies that detect one of these offences draw up the report and send it to the ACT.

Does time waiting for trips count towards the 10 hours?

The law does not answer directly. It uses the expression "operate TVDE vehicles" and does not define it. Nor does it say whether the 24-hour period is a calendar day or a rolling period. These questions depend on interpretation and on how the ACT and the platforms apply the rule.