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TVDE platform manager licence: requirements and deadlines

Platforms such as Uber, Bolt and others need a licence from the IMT. The new law adds requirements, creates the concept of technological capacity, puts an expiry date on the licence and requires platforms already licensed to obtain a new licence within one year.

The short answer

To run a TVDE platform in Portugal you need a licence from the IMT, Portugal’s transport authority, requested electronically. The IMT decides within 30 working days counted from payment of the fee; without a decision, the application is deemed approved (article 17(1)). The licence lasts a maximum of five years and is renewable. Platforms that were already operating keep their licence, but have 120 days from 1 September 2026 to demonstrate their technological capacity and one year to obtain the new licence (article 4 of Law no. 59/2026).

This article is about licensing. For the role of the platforms, the intermediation fee and the contribution, see platforms and operators.

Who needs this licence

The law defines electronic platforms as infrastructures owned or run by legal persons that act as intermediaries between users and TVDE operators through an app (article 16). Whoever runs them is the electronic platform manager. Not to be confused with the TVDE operator, which is the one with the cars and drivers and needs a different licence, explained inTVDE operator licence.

If the platform manager is not based in Portugal, it must notify the IMT of a representative in Portugal (article 17(5)). Portuguese law applies to services provided in Portugal, wherever the platform is based, and Portuguese courts have jurisdiction over disputes with consumers (article 21).

The licensing requirements

Article 17(4) is no longer a list of documents to be submitted but a list of requirements. The comparison with 2018 shows what is new.

Requirements in article 17(4)

topic	2018 law	new law
identification	company name, tax number, registered office and email address	full identification, with legal representative, registered office and email
tax and social security status	not required	clean record
trademark	name or trademarks adopted	registration number of the trademark adopted
good repute	criminal record certificates of office holders	good repute, assessed under article 18
technological capacity	did not exist	new requirement, with five points (article 17-A)
standard contract terms	not required	sent to the AMT
articles of association and public registers	required	required

Documents already held by a national administrative authority do not have to be submitted, as long as the applicant authorises the IMT to obtain them (article 17(6) and (7)). The new article 20-B strengthens this automatic retrieval, which covers criminal records, tax status and social security status.

Good repute of directors

Good repute is assessed in relation to the members of the board, management or executive bodies, in particular through their criminal record (article 18). The following are not of good repute: those legally prohibited from engaging in trade, those convicted by final judgment of crimes relating to pay, health and safety at work, the environment or professional liability, and those disqualified as a result of bankruptcy or insolvency. Rehabilitation and the time that has passed may be taken into account. The platform manager must send the IMT the criminal record of these office holders every year, or authorise it to be obtained. These rules already existed in 2018.

Technological capacity: the five requirements

This is the big change in licensing. Article 17-A says technological capacity is assessed by compliance with five requirements of the platform itself. For anything the law does not cover, Decree-Law no. 7/2004 of 7 January applies.

a
Integration with the IMT databases
The platform connects to the IMT as provided by law, which refers to the data-sharing platform in article 20-A, membership of which is mandatory.
b
Recording working time
The platform records the driver’s working time and ensures compliance with driving and rest limits, including the ten hours in every 24 in article 13.
c
Data protection
Compliance with the general personal data protection regime. Systems are certified by an audit supervised by the CNPD, the national data protection authority (article 20(2)).
d
Access for enforcement bodies
Enforcement bodies access the information strictly necessary for their powers, as provided in article 20-A.
e
Emergency service
Real-time phone connection with the authorities and sharing of the vehicle’s location, for users and drivers (article 19(1)(j)).

Two of the five requirements depend on an implementing regulation

Integration with the IMT and access for enforcement bodies refer to article 20-A, whose technical definition (formats, deadlines, access profiles, encryption) depends on an implementing regulation (portaria) not yet published in September 2026. The 120-day deadline runs regardless. See the missing implementing regulationsand the IMT data platform.

The application and the decision

The application is made through the electronic channel provided or indicated by the IMT. In 2018 the law pointed to the Entrepreneur’s Desk; that reference has disappeared. The IMT examines and decides within 30 working days, and the count starts with payment of the fee, a new detail that was not in the previous version. Without a decision within that period, there is tacit approval. Failing to meet any requirement is grounds for rejection (article 17(2)).

Once licensed, the platform manager must keep the licensing details on the platform itself, for anyone interested to consult, except for the office holders and the articles of association (paragraph 8). The IMT publishes on its website the list of authorised platform managers, with the details in paragraphs (a) to (e) of paragraph 4 (paragraph 9).

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 (paragraph 12). Renewal is requested six months in advance (paragraph 13). Changes to the access or operating requirements must be notified to the IMT within 10 working days (paragraph 14). All these rules are new: in 2018 the platform licence had no term, nor rules on renewal or on notifying changes.

Note an asymmetry: for operators, the notification deadline is 10 days from when the change occurs, with no mention of working days (article 3(10)), and failing to notify carries its own fine, paragraph (c). For platforms, the list of offences has no paragraph equivalent to paragraph 14.

When the requirements fail: revocation on its own initiative

If a requirement stops being met after the licence is granted, the body that detects it sets a deadline for remedying the shortcoming (paragraph 15). Once the deadline passes without correction, a licence revocation procedure is started on its own initiative (paragraph 16). Regardless of this, the IMT may order the suspension, restriction or termination of the activity in case of non-compliance (paragraph 10). Merger operations between platform managers must be notified to the AMT (paragraph 17).

The transition for platforms already licensed

Article 4 of the body of Law no. 59/2026 sets fixed deadlines, which should not be confused with the disputed deadlines in article 32 of the annex:

120 days from entry into force, on 1 September 2026, for platform managers to demonstrate the technological capacity of article 17-A (paragraph 1).
One year, until 1 September 2027, to demonstrate the access requirements of article 17, after which a new licence is issued to them with the validity in paragraph 12 (paragraph 3). Issuing the new licence causes the previous one to lapse (paragraph 4).
Licences issued under the 2018 law remain valid until the end of their term, with renewal under the new law (paragraph 2).

Since 2018 platform licences had no validity period, in practice it is paragraph 3 that sets the timetable: by September 2027, all platforms will have to pass the new test.

Fines linked to licensing

Carrying out the platform manager activity without a licence is article 25(2)(v), attributed to the platform manager and processed by the IMT, with a fine of 5,000 to 44,000 euros for legal persons. Not having the working-time recording system, paragraph (y), or failing to comply with the data platform duties, paragraph (aa), are separate offences. The full list is in the list of TVDE fines. Remember too that the platform manager may not hold operators, training schools or vehicles: seeincompatibilities.

Frequently asked questions

How long does it take to get a TVDE platform manager licence?

The IMT has 30 working days to decide, counted from payment of the fee due. If it does not decide within that period, the application is deemed tacitly approved (article 17(1)). The law does not set the amount of the fee, which is up to the competent body (article 29).

How long is the platform licence valid?

A maximum of five years, renewable for equal periods as long as the requirements are still met (article 17(12)). The renewal application must be submitted six months in advance (paragraph 13). Under the 2018 law, article 17 set no validity period at all.

Do Uber and Bolt need a new licence?

Yes. Article 4(3) of Law no. 59/2026 requires platform managers already licensed to demonstrate, within one year of entry into force, the requirements of article 17, after which a new licence is issued to them. Issuing the new licence causes the previous one to lapse. Before that, within 120 days, they must demonstrate their technological capacity.

Can a platform based outside Portugal operate?

Yes, as long as it is licensed by the IMT. It must notify the IMT of a representative in Portugal, identified with the same details required for licensing (article 17(5)). Portuguese law applies to services provided in Portugal, wherever the platform is based (article 21).

What happens if a platform stops meeting the requirements?

The body that detects the shortcoming grants a deadline to remedy it. If the deadline passes without correction, a licence revocation procedure is started on its own initiative (article 17(15) and (16)). The IMT may also order the suspension, restriction or termination of the activity (paragraph 10).