The short answer
You complain inside the app itself. Article 19(2) of the TVDE law requires every platform to have an electronic complaints button, visible on the main page, leading to an Electronic Complaints Book available on the platform. After receiving the complaint, the platform must investigate what happened, correct it if appropriate and keep a record for at least two years. If the reply does not satisfy you, you can turn to alternative dispute resolution, the regulators or the Portuguese courts.
Almost all of this mechanism already existed in 2018. The 2026 revision added trip ratings by the driver, rules on subscriptions and accessibility, and changed who applies the fines.
Step by step
What the app must give you
Article 19(2) lists what platforms must provide "for the purpose of users’ complaints about the service, or the exercise of supervisory powers by the competent bodies":
- an electronic complaints button, visible and easily accessible on the main page, redirecting to an Electronic Complaints Book available on the platform, item (a);
- information on alternative dispute resolution, under Law no. 144/2015, item (b);
- a trip rating service by the user and by the driver, item (c);
- if there are subscriptions, account management and the option to cancel at the user’s request, item (d);
- the accessibility and usability rules in force, item (e).
In addition, para. 1 of the same article requires the app to show, before and during each trip, the driver’s identification with the unique registration number and photo, the photo and registration plate of the car, the price and the calculation formula, and the route on a digital map in real time. This is the information that serves as evidence in a complaint.
What the platform must do with your complaint
Article 19(3) says that, after receiving a complaint, the platform operator "must take the steps necessary to investigate and, where necessary, correct the reason that gave rise to it". It must also keep a record of complaints and the related procedure for a period of no less than two years from the date of the complaint.
That record is useful to you: if the complaint goes to a regulator or to court, the platform must be able to show what it did. Failing to keep the record is an administrative offence, under article 25(2)(z). The law sets no deadline for the platform to reply to the passenger.
The platform is liable, even if someone else is at fault
In a TVDE trip there are three parties: the driver, the TVDE operator that engages them and the platform. Article 20(1) makes life simpler for the passenger: the platform operator is jointly and severally liable to users for the timely performance of the contract’s obligations. You can therefore go to the platform and demand a solution, without having to find out whose fault it was.
Alternative dispute resolution
If the platform’s reply does not solve the problem, article 22 allows consumer disputes to be resolved out of court, under Law no. 144/2015. The app must inform you about this route, under article 19(2)(b). While the process is under way, the time limit for bringing a court action or an order for payment procedure is suspended, so you lose no rights by trying this first.
The regulators: the AMT and the IMT
Article 23 says that the activity of platforms, TVDE operators, vehicles and drivers is supervised, in particular, by the AMT (the mobility and transport regulator) and the IMT (Portugal’s transport authority). Enforcement also falls to the ACT (labour inspectorate), Social Security, the GNR, the PSP, the Tax Authority and the National Data Protection Commission, each in its own area, under article 24.
To know who to contact, see what the law says about who handles each administrative offence, in article 25-A:
- AMT: discrimination, refusal of service, refusal of animals, duties towards passengers with reduced mobility, missing mandatory information in the app, missing complaints button or information on alternative dispute resolution, missing complaints record.
- IMT: picking up passengers on the street, prices charged against the law, missing information on the price formula or the invoice, vehicles and drivers not meeting the requirements.
If you send the complaint to the wrong body, all is not lost: under article 25-A(3), a body that detects facts outside its competence draws up a report and sends it to the competent body. If a crime is involved, such as an assault, the route is the police.
Where is the complaints book for a TVDE ride?
In the app itself. Article 19(2)(a) requires platforms to have an electronic complaints button, visible and easily accessible on the main page, that redirects the user to an Electronic Complaints Book, also available on the platform. You do not need to ask the driver for it.
How long does the platform have to reply?
The TVDE law sets no deadline. Article 19(3) requires the platform to take the necessary steps to investigate and, where necessary, correct the reason for the complaint, and to keep a record of complaints and the procedure for at least two years. Reply deadlines, if any, come from other regimes that this law does not detail.
Can the platform say the driver or the TVDE operator is to blame?
It can say so, but that does not release it from its obligations to you. Article 20(1) makes the platform operator jointly and severally liable to users for the timely performance of the obligations arising from the contract. You can demand performance directly from the platform.
Uber or Bolt have their registered office outside Portugal. Can I complain here?
Yes. Article 21 applies Portuguese law, notably on consumer protection, to services provided on national territory, regardless of where the platform operator has its registered office. And the Portuguese courts have jurisdiction over any dispute between a consumer and a TVDE operator or a platform.
Which body should I complain to: the AMT or the IMT?
It depends on the problem. Under article 25-A, the AMT handles, among others, offences of discrimination, refusal of service, reduced mobility, app information and complaints. The IMT handles street pick-ups, prices charged against the law and missing price or invoice information. A body that receives facts outside its competence must send them to the competent body.
Does going to an arbitration centre make me miss the deadline to go to court?
No. Article 22(2) says that, when the parties opt for out-of-court consumer dispute resolution, the time limit for bringing a court action or an order for payment procedure is suspended while those mechanisms are under way.