Netherlands CDT: taxi records and the 2028 deadline

Start with the transport category, including pre-booked transfers

The Wet personenvervoer 2000 defines taxivervoer as passenger transport by car for payment that is not public transport. A car is built to carry no more than eight people, excluding the driver. The separate category of besloten busvervoer concerns buses; there is no equivalent general category of private car transport. Our inference from these definitions is that advance booking alone does not turn an airport transfer, corporate journey or chauffeur service by car into another transport category. This is a reading of the definitions, not a determination for every individual service. Rijksoverheid (Overheid.nl) — Wet personenvervoer 2000, article 1.

There are exemptions. The Besluit personenvervoer 2000 excludes, among other activities, transport for weddings and funerals and ambulance transport. The Act also excludes car transport where payment does not exceed the car's costs, unless it is provided professionally. We have not examined individual exemptions under article 76(5). Assess the service actually delivered, rather than relying on the words limousine or private transfer on a website. Rijksoverheid (Overheid.nl) — Besluit personenvervoer 2000, article 2.

Article 76 of the Act requires a taxi transport licence, with conditions concerning reliability and professional competence; the licence document must be visible to the passenger. According to Ondernemersplein, applications go to Kiwa Register. The licence has no end date, but Kiwa checks continued compliance every five years. Its personenvervoernummer, or P-number, must appear on the taxi information card and the ride receipt. Ondernemersplein (KVK/RVO) — Applying for a taxi licence. Rijksoverheid (Overheid.nl) — Wet personenvervoer 2000, article 76.

The move from BCT to CDT: which date matters?

The legal basis is the decree of 25 April 2025, published as Staatsblad 2025, 161. It amends the Besluit personenvervoer 2000 and the Arbeidstijdenbesluit vervoer. Articles I and III took effect on 1 July 2025; articles II and IV take effect on 1 January 2028. The explanatory note describes the intervening period as a transition during which operators choose when to switch. The official expansion of CDT is Centrale Database Taxivervoer. Rijksoverheid — Staatsblad: Decree of 25 April 2025.

The transition therefore continues through 31 December 2027. Operators that have not moved to CDT remain subject to the applicable BCT rules. Article 79 requires a type-approved, activated on-board computer for that system. From 1 January 2028, taxi transport can only operate under CDT. Use that final date to plan the change, while assessing present recording obligations against the system your business actually uses. Rijksoverheid — Recording taxi journeys and working time.

Which twelve groups of data must be recorded?

Article 83b(2) places responsibility on both the carrier and the driver: a suitable recording device must correctly register the data below. The list covers more than a booking or a completed journey. Work activities and working and rest times are included too. These are all twelve items, in the order used by the article. Rijksoverheid (Overheid.nl) — Besluit personenvervoer 2000, article 83b.

1. The car's registration number.
2. The date and time when work on board the car begins and ends.
3. The driver's working and rest times.
4. The personenvervoernummer, or P-number.
5. The KvK business registration number referred to in article 9a of the Handelsregisterwet 2007.
6. The driver's driving licence number.
7. The chauffeursnummer, or driver number.
8. The date and time of arrival and departure for each journey.
9. The departure location for each journey.
10. The distance for each journey.
11. The transport price for each occupied journey and any surcharges charged.
12. Other work activities.

The driving licence number and the chauffeursnummer are separate data items; an internal driver reference does not replace them. According to the explanatory note, the arrival location was removed from the CDT list. Passenger data is not registered in CDT either. A customer's name, telephone number or flight details may help deliver a booking, but that does not make them CDT fields. Staatssecretaris van Infrastructuur en Waterstaat — CDT regulation, explanatory note.

The minister operates CDT for supervision of transport requirements and working and rest times. The carrier is the data controller for its recording device and submits the information in real time. ILT receives the data and supervises through digital, business and roadside inspections; breaches of working and rest times can lead to fines. Rijksoverheid — Recording and supervision. Rijksoverheid (Overheid.nl) — Besluit personenvervoer 2000, articles 83a and 83b.

Real-time delivery needs a working recording process

The Regeling centrale database taxivervoer has applied since 1 July 2025. A recording tool can take different forms, including an app, but must meet its requirements. These include location accuracy of at least 25 metres, time accuracy of at least one second, driver authentication and distance measurement within 15%. Data must not be changeable before delivery. The carrier's ICT solution and organisation require ISO 27001 certification from an accredited body. Staatssecretaris van Infrastructuur en Waterstaat — Regeling centrale database taxivervoer.

Data passes through the carrier's central application to the CDT Meldingen API. The only exceptions to real-time delivery are API unavailability or disruption of transmission; the data must then be delivered without delay afterwards. An ordinary daily export is therefore no substitute. A failed recording device must be repaired or replaced within three working days. Meanwhile, the driver records the information in another verifiable way and hands it in by the third working day. Staatssecretaris van Infrastructuur en Waterstaat — Articles 2, 3, 7 and 9.

• Check before first use: the carrier must validate every driver and car. Assign responsibility for this check when a new person or vehicle joins the operation.
• Rehearse the working day: logging on and off for work, journeys and breaks. The regulation treats a break as at least fifteen consecutive minutes.
• Check fare recording: without a taximeter connection, the driver enters the total price manually. This does not settle when a taximeter is mandatory; we have not researched that question here.
• Ask the supplier to demonstrate the path from recording to delivery, including a disruption. Decide who follows up undelivered data and who reports a defective device.

Retention: two years in CDT is not a general archive policy

Article 83a(3) states that data is kept in the central database for two years and then destroyed. That period identifies where the records are retained: inside CDT. We do not read it as a general retention period for your own booking records, CRM or entire business administration. Assess those separately, according to the records involved and the obligations that apply to them. Rijksoverheid (Overheid.nl) — Besluit personenvervoer 2000, article 83a.

For old on-board computer records, article 83f(4) introduces a different rule from 2028: transfer them to the carrier's establishment and keep them there for at least 104 weeks. Include that transfer in the migration plan. Having a working new app does not establish where the old records will go or how the business will retrieve them later. Rijksoverheid — Staatsblad: Transitional provisions, article 83f.

Common mistakes when switching systems

A hotel contract is not a general exemption from taxi requirements. Article 73(4) provides for a possible ride-receipt exception for a written agreement covering repeated journeys over a period at a fixed tariff. That is a specific issue. We have not read the underlying ride-receipt regulation and draw no conclusion about the documents your particular operation must provide. Rijksoverheid (Overheid.nl) — Besluit personenvervoer 2000, article 73.

Switching does not remove driver-document requirements either. The chauffeurskaart remains required during the transition. From 2028, the legislation specifies a valid, readable chauffeurspas; cards issued earlier may serve as that pass until they expire. According to the explanatory note, the registered chauffeursnummer replaces the chauffeurskaart number. Check the actual identifier, rather than simply carrying an old field name into a new system. Rijksoverheid — Staatsblad: Driver passes and transitional provisions.

Other mistakes include treating a planned collection time as an actual recorded journey event, sending passenger data because it already exists in the CRM, or assuming an export button is a CDT connection. We recommend checking booking records, operational events and statutory registration separately, then establishing where they should agree. This makes it clear which system records which information and who can investigate a discrepancy.

Where TransferCRM helps

In TransferCRM, we store booking and ride details, timestamps, and the driver and vehicle assigned to each ride; data can be exported. This supports daily administration and looking up a completed assignment. TransferCRM does not submit data to government registers, including CDT. For CDT, you need a separate recording solution that meets the applicable requirements.