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TVDE operator licence: the legal procedure, step by step

What the law says about applying to the IMT for an operator licence after the 2026 revision: who can apply, what items to submit, how it is decided, how long it lasts and what you must do to keep it.

The short answer

The TVDE operator licence is requested from the IMT, Portugal’s transport authority, electronically, with nine application items that now include the trademark registration number and proof of a clean tax and social security record. The IMT has 30 working days, counted from payment of the fee, to decide; if it does not, the application is deemed approved. The licence lasts a maximum of five years, compared with ten under the 2018 law, and renewal must be requested six months before the end (article 3 of the revised regime).

This article deals only with the legal licensing procedure. For setting up the company, the fleet and the relationship with the platforms, see theguide to setting up a TVDE operator.

  1. 1

    Confirm you can apply

    The law assigns the operator activity to legal persons (article 2(1)) and excludes anyone with links to TVDE driver training bodies.

  2. 2

    Gather the nine items

    The application items in article 3(4), which now include the trademark registration number and proof of a clean tax and social security record.

  3. 3

    Check the managers’ good repute

    Everyone holding a position on the board, in management or as a manager must be of good repute under article 4.

  4. 4

    Submit and pay the fee

    The application is made through the electronic channel indicated by the IMT. The decision deadline only starts running once the fee is paid.

  5. 5

    Wait for the decision

    The IMT decides within 30 working days. Without a decision, there is tacit approval, notified electronically.

  6. 6

    Keep the licence

    Valid for up to five years, renewal requested six months before, changes notified within 10 days and the managers’ criminal record sent every year.

1. Who can apply

Article 2(1) says the operator activity is carried out "by legal persons that provide paid individual passenger transport". Legal persons holding a taxi operator permit can also be TVDE operators, by going through this same licensing (article 2(4), new in 2026).

There is a new exclusion: the operator may not own, finance or have an interest, directly or indirectly, in TVDE driver training bodies (article 2(9)), and the bodies that run the courses may not be operators (article 10(11)). Seeincompatibilities in TVDE.

2. The application items

Article 3(4) lists what the applicant must send to the IMT. Two paragraphs changed in 2026.

Application items in article 3(4)

topic2018 lawnew law
(a) to (c)company name, tax number, registered officeunchanged
(d) trademarkname or trademarks adopted for the operationnational or European registration number of the trademark adopted
(e) email addressrequiredunchanged
(f) managementoffice holders and their criminal recordsunchanged
(g) and (h) articles and registrationsarticles of association, entries in public registersunchanged
(i) tax and Social Securitynot requiredproof of a clean tax and social security record

Trademark registration is the requirement that may cause the most work for newcomers. A national or European registration is a separate procedure, with deadlines that do not depend on the IMT. It is worth dealing with it before preparing the licence application.

You do not have to submit documents already held by a national administrative authority if you authorise the IMT to obtain them (article 3(5) and (6)). The new article 20-B extends this automatic retrieval, through the Public Administration Interoperability Platform, to criminal records, tax status and social security status. If the lookup is not possible, the IMT notifies you to submit the documents within a deadline; if you do not, the application is rejected (article 20-B(4) and (5)).

3. The managers’ good repute

The operator’s good repute is assessed in relation to the members of its board, management or executive bodies, in particular through their criminal record (article 4(1)). The following are not of good repute: those legally prohibited from engaging in trade, those convicted by final judgment of crimes relating to the pay regime, health and safety at work, the environment or professional liability, and those disqualified as a result of bankruptcy or insolvency while the disqualification lasts.

A conviction does not rule out good repute for someone who has been rehabilitated, and the IMT may, with reasons, consider someone of good repute despite a conviction, taking into account the time that has passed (paragraph 3). These criteria differ from those that apply to drivers, explained in driver good repute. Good repute is not checked only once: the operator must send the IMT the managers’ criminal record every year, or authorise it to be obtained (paragraph 4).

4. Submit the application and pay the fee

The application is made "through the electronic channel provided or indicated by the IMT". The 2018 law required the use of the Entrepreneur’s Desk, with an alternative form in case it was unavailable; that rule was repealed. The amount of the fee is not in the law: fees are set by the competent bodies (article 29).

5. The decision and tacit approval

The IMT examines and decides the application. If no decision is made within 30 working days of payment of the fee, the application is deemed tacitly approved (article 3(1)). The difference from 2018 lies in when the count starts, which is now payment of the fee. Once the deadline has passed, the applicant is informed electronically that tacit approval has taken effect, under the Code of Administrative Procedure (paragraph 7). If a requirement is missing, the application is rejected (paragraph 2).

I paid the fee 35 working days ago and the IMT has not replied. Do I have a licence?

allowed

Under article 3(1), the application is deemed tacitly approved when 30 working days pass without a decision after payment of the fee, and the IMT must inform you of this electronically. Keep the proof of payment and the date. But be careful: if the IMT notified you to submit missing documents, you need to see how that affects the deadline.

6. Validity, renewal and changes

The licence is issued for a period of no more than five years, renewable for equal periods as long as the requirements are still met (article 3(8)). In 2018 the limit was ten years, with five-year renewals. The renewal application must be submitted six months in advance (paragraph 9), a rule that did not exist before.

The licence’s validity has a knock-on effect: each vehicle’s registration with the IMT is valid for five years, but never longer than the operator’s licence (article 12(4)). A licence close to expiry shortens the cars’ registration. Seevehicle registration with the IMT.

Changes to the access or operating requirements must be notified to the IMT within 10 days of the date on which they occur (paragraph 10). A change of management, registered office or tax status are examples. This obligation is new and carries its own fine.

My licence was issued in 2021 for ten years. Is it still valid?

allowed

Yes. Article 4(2) of Law no. 59/2026 keeps licences issued under the 2018 law valid until the end of their term. Renewal, however, follows the new law: an application six months before the end and a licence renewed for a maximum of five years.

The public list of operators

The IMT keeps on its website the list and contact details of authorised operators (article 3(11)). This is a new rule for operators; in 2018 the law only provided for a list of platforms. For a driver, it is a simple way to confirm that the operator they are about to sign with is licensed.

After the licence

The licence is the starting point. The operator must ensure the operating requirements are met at all times, including those for vehicles and drivers, failing which the IMT may order the suspension, restriction or termination of the activity (article 9(1)). It is liable for giving platform access to drivers who do not meet the requirements (article 14(3)), must have a written contract with each driver (article 10(2)(e)) and must notify the AMT of merger operations (article 9(3)). See alsothe contract between driver and operator.

What you risk by operating without a licence

Carrying out the operator activity without a licence is article 25(2)(b), attributed to the operator and processed by the IMT. Failing to notify changes is paragraph (c). In both cases, the fine for legal persons ranges from 5,000 to 44,000 euros, and a ban on the activity of up to two years may be ordered. See the full list of fines.

Frequently asked questions

How long does it take to get a TVDE operator licence?

The IMT has 30 working days to decide, counted from payment of the fee due. If there is no decision within that period, the application is deemed tacitly approved and the applicant is informed electronically (article 3(1) and (7)). If the IMT needs documents it could not obtain on its own, it notifies the applicant and sets a deadline for submitting them.

How long is the operator licence valid?

Under the new law, a maximum of five years, renewable for equal periods as long as the requirements are still met (article 3(8)). Under the 2018 law the licence could be issued for up to ten years, with five-year renewals. Licences issued before 1 September 2026 remain valid until the end of their term.

Do I have to register a trademark to get an operator licence?

Among the application items, the law requires the national or European registration number of the trademark adopted for the operation (article 3(4)(d)). In 2018 it was enough to state the name or trademarks adopted. The law does not clarify whether having filed the registration application is enough; check with the IMT before submitting.

Can a sole trader be a TVDE operator?

Article 2(1) says the operator activity is carried out by legal persons, and that rule was not changed in 2026. The text of the law does not provide for sole traders. If that is your situation, check directly with the IMT before going ahead.

I changed managers. Do I have to tell the IMT?

Yes. Changes to the access or operating requirements must be notified to the IMT within 10 days of the date on which they occur (article 3(10)). Failure to notify, or late notification, is an offence (article 25(2)(c)), with a fine of 5,000 to 44,000 euros for legal persons.

When should I apply for renewal?

Six months before the end of the validity period (article 3(9)). The law does not expressly say what happens to an application submitted after that deadline, but operating with an expired licence is carrying out the activity without a licence, paragraph (b) of the fines.

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