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The missing implementing regulations: what the new law left unregulated

Law no. 59/2026 is in force, but several rules only work once the Government publishes implementing regulations (portarias). This table shows each planned act, the article that calls for it, what it will define and what is on hold until then.

The short answer

Five implementing regulations are missing, all to be approved by the government minister responsible for mobility: the one on the identification sticker, the one on driver training, the one on checking functional command of Portuguese, the one on the technical definition of the IMT data-sharing platform and the one on access by the Tax Authority and Social Security to that platform. Until they are published, the rules that depend on them are in the law but have no practical way of being complied with or enforced.

The law sets no deadline for any of these regulations. Nor does it say, as a rule, what applies in the meantime. The table below reflects the situation in September 2026.

Status: September 2026

At the date of this page, none of the five implementing regulations had been published in the official gazette (Diário da República). We update the table when publications appear. See also the timeline of updates.

Regulation tracking table

act	provided for in	what it will define	what is on hold	status
Sticker regulationgovernment minister for mobility	art. 12(15)	Design, technical features, security elements, conditions for issuing, replacing, cancelling and validating, and the fee for the sticker.	The non-removable sticker with anti-fraud features (paragraph 10) and the QR code for public validation (paragraphs 13 and 14).	not published
Training regulationgovernment minister for mobility	art. 10(12)	Allocation of the 50 hours of the initial course and the 8 hours of the continuing course across modules; teaching and trainer requirements; recognition, suspension and revocation of training bodies; final assessment, authorisation of exam centres, certificates and notification to the IMT.	The practical organisation of the new 50-hour initial course and of the final assessment carried out by the IMT or by an exam centre it authorises.	not published
Portuguese language regulationgovernment minister for mobility	art. 10-A(3)	Content, criteria and procedures for checking functional command of Portuguese.	The Portuguese check built into the training course, on which completion of the initial course now depends.	not published
Technical regulation for the data platformgovernment minister for mobility	art. 20-A(7)	Data to be transmitted, deadlines, frequency, formats, access profiles, access control, operation logs, audit trails, encryption, retention, deletion and security.	The mandatory connection of platforms to the IMT, the validation of operators, drivers and vehicles through it (art. 20(6) and (7)) and, in practice, fine paragraph (aa).	not published
Regulation on access by the Tax Authority and Social Securitygovernment minister for mobility, after consulting the AT and the ISS	art. 20-A(5) and (6)	Which information the AT and the ISS may consult or receive to check tax and social security obligations; the practical arrangements may be set out in a technical protocol with the IMT.	Tax and social security cross-checking through the IMT platform and fine paragraph (ff).	not published
IMT decision on the certificate designIMT board of directors	art. 10(2)(d); art. 32(2)	The design of the TVDE driver certificate, with the unique registration number.	Nothing, in principle: paragraph (d) was not amended and the design has been provided for since 2018.	unconfirmed whether there will be a new design
AMT form for the monthly reportAMT board of directors	art. 30(4)	The template platforms use to send the AMT the number of trips, the amount invoiced and the intermediation fee charged.	Nothing, in principle: the text of this paragraph dates from 2018.	provided for since 2018
Order setting up the advisory bodygovernment minister for mobility	art. 20-C	Composition, operation and rules of an advisory body to monitor the sector.	Nothing. Setting it up is optional ("may create") and the body has no decision-making powers.	optional

The sticker: the most visible regulation

In 2018 the sticker was removable and defined by a decision of the IMT board of directors. The new wording of article 12 requires a non-removable sticker, with anti-fraud security features such as holograms, issued by the IMT, visible from outside and linked to the vehicle’s registration (paragraph 10). It will also have a QR code allowing anyone to confirm just four things: that the vehicle is authorised, the registration plate, the operator licence number and the existence of valid insurance (paragraphs 13 and 14).

All of this depends on the implementing regulation in paragraph 15, which also sets the fee. Fine paragraph (o), which punishes breaches of the rules on displaying, issuing or validating the sticker, refers precisely to these paragraphs. Details inthe new TVDE sticker.

Training and Portuguese: what is already in the law and what is missing

The new law put into the text itself the minimums that in 2018 were left to an implementing regulation: an initial course of at least 50 hours, with theoretical and practical components and six subjects; attendance of 80% of the hours of each module; a final assessment of 30 questions with at least 27 correct, carried out by the IMT or by an authorised exam centre; eight hours of continuing training to renew (article 10(6) to (9)). The regulation in paragraph 12 allocates those hours across modules and governs training bodies and the exam.

The Portuguese check is a separate case. Article 10-A builds it into the training course and makes completion of the initial course depend on it, but leaves the content, criteria and procedures entirely to an implementing regulation. The law does not say what level is required. See TVDE driver training and theexam.

The data platform and tax authority access

Article 20-A requires platforms to join the IMT data-sharing platform and to ensure the connection, transmission and updating of data. But the technical definition of all of this, from formats to encryption measures, is left to the regulation in paragraph 7. Access by the AT and the ISS to tax and social security information is left to the regulation in paragraphs 5 and 6. The law does not say whether the two matters will be dealt with in one regulation or two. More in the IMT data platform.

A fixed deadline that depends on an uncertain regulation

Article 4(1) of Law no. 59/2026 gives platforms 120 days from entry into force to demonstrate the technological capacity of article 17-A. Two of the five requirements are integration with the IMT databases and access for enforcement bodies under article 20-A. Without the technical regulation, it is not defined how that integration is to be done. The deadline is fixed; what is missing is how to meet it.

Other planned acts that hold nothing up

Some acts provided for in the law are not new or not mandatory. The design of the driver certificate has been approved by decision of the IMT board of directors since 2018, and article 10(2)(d) was not amended. The 30-day deadline in article 32(2) for approving that design is 2018 text reproduced in the republication. We do not know whether the IMT will approve a new design, for example to reflect the unique registration number assigned to taxi drivers.

The AMT form for the platforms’ monthly report also dates from 2018. Procedure fees, such as those for the licence or the certificate, are set by the competent bodies (article 29) and not by implementing regulation. The advisory body in article 20-C is optional. And the autonomous regions may approve complementary measures by regional legislative decree (article 32-A), but that is their choice, not a condition for the law to apply. Seeregions and local rules.

What no longer needs an implementing regulation

The revision also went the other way. The platforms’ contribution, which in 2018 ranged from 0.1% to 2% as set by an implementing regulation, is now a fixed 5% set in the law (article 30(2)). The minimum hours of the course, which in 2018 were "to be defined by implementing regulation", are now in the text. These rules apply without waiting for anything else.

What about the 60-day and 120-day deadlines?

Do not confuse these regulations with the transitional regime in article 32 of the annex, whose 60-day and 120-day deadlines are disputed by APTAD because they are unamended 2018 text. That debate is explained in when the new law comes into force. The deadlines in article 4 of the body of the law, however, are certain: 120 days for the platforms’ technological capacity, one year for the new platform licence, and old licences valid until the end of their term.

Frequently asked questions

Which implementing regulations under the new TVDE law are yet to be published?

Five matters depend on an implementing regulation (portaria) from the government minister responsible for mobility: the sticker (article 12(15)), training (article 10(12)), the Portuguese language check (article 10-A(3)), the technical definition of the data-sharing platform (article 20-A(7)) and access by the Tax Authority and Social Security to that platform (article 20-A(5) and (6)). In September 2026 none had been published.

Do I have to replace my sticker now?

It is not physically possible until the implementing regulation defines the design, issuing conditions and fee for the new sticker, which is issued by the IMT. The law has no specific transitional rule for the current sticker. The prudent approach is to keep the sticker you have, in good condition, and follow the publication of the regulation.

Until the training regulation comes out, can I take the TVDE course?

The law does not expressly settle this question. It already sets the minimums (50 hours, 80% attendance per module, a 30-question test with 27 correct answers), but leaves to an implementing regulation the organisation of the courses, the recognition of training bodies and the exam procedures. Check with the training body and the IMT under which rules the course is being run.

If the Portuguese language regulation does not exist, does the requirement already apply?

The law says the content, criteria and procedures for the check are defined by an implementing regulation. Without it, there is no defined way to carry out the check, so the requirement cannot be applied in practice. Certificates already issued remain valid until the end of their term.

Does the platforms’ 5% contribution also wait for an implementing regulation?

No. Under the 2018 law the percentage, between 0.1% and 2%, was set by an implementing regulation. The new wording of article 30 sets a single percentage of 5% in the law itself, so it does not depend on further regulation.