Spain VTC register: what to report before each ride

Who submits the details, and since when?

Article 1 places the obligation on holders of authorisations for vehicle hire with a driver, known as VTC. When organising office work, distinguish the person who receives a booking, the person who assigns a vehicle and the person who submits the details. Sharing those tasks does not change whom the legislation identifies as responsible. The deadline relates to the start of each individual service, rather than the end of a shift or a daily administration session. Ministerio de Transportes, Movilidad y Agenda Urbana — Real Decreto 785/2021.

Royal Decree 785/2021 entered into force on 3 October 2021. The Directorate-General for Land Transport’s Resolution of 26 October 2021 set the VTC service communication register, or RVTC, as operational from 1 February 2022, covering services starting from that date. These are separate milestones: the decree becoming law and the register becoming operational. Keeping them separate helps when reading older explanations of the reporting requirement. Dirección General de Transporte Terrestre — Resolución de 26 de octubre de 2021.

What to prepare for each submission

The following list summarises Article 1 of Royal Decree 785/2021. We use it to distinguish the information required for the submission from other details that may help the office organise a transfer: Ministerio de Transportes, Movilidad y Agenda Urbana — Real Decreto 785/2021.

• Lessor and intermediary: name and Spanish tax identification number, or NIF. Check that each identity belongs to the relevant party, rather than substituting the passenger’s identity.
• Conclusion of the contract: place, date and time. The time the contract is concluded and the scheduled pickup time describe different events.
• Start of the service: place, date and time. These should remain distinguishable from the contract details when reviewing the booking.
• End of the service: place and date. The end location may be omitted where the contract expressly states that the client will choose it freely during the service.
• Vehicle: registration number. Checking it alongside the vehicle assignment helps identify a mismatch between the service record and the car now scheduled to perform it.
• A journey starting and ending at the same location: the decree includes the furthest point of the route, but limits that requirement to the transitional period under Royal Decree-law 13/2018. We do not describe it as a permanent obligation.

Why passenger details are excluded

The preamble to Royal Decree 785/2021 explains that the Supreme Court annulled the earlier provision covering users’ personal data because that processing was disproportionate. The current list of information to be communicated leaves out the service users. The office should therefore not automatically transfer everything a customer supplied for arranging a journey into the RVTC submission. Ministerio de Transportes, Movilidad y Agenda Urbana — Real Decreto 785/2021.

In practical terms, we recommend reviewing the operational booking record separately from the fields intended for the administrative submission. A contact telephone number may help the office coordinate a pickup, but that does not make it a field that must be sent to the register. This separation is an organisational recommendation, not an additional statutory field requirement. It also makes a review more focused: compare the required fields instead of treating a larger export as a better submission.

Organising submission before the journey starts

The DGTT resolution provides for a web application on the Ministry’s electronic office and a web service for companies’ own software. The web application uses Cl@ve or certificate authentication. Authorisation holders and their accredited representatives may access it. The web service requires prior enrolment and a legal-entity representative certificate. Having booking software therefore does not, by itself, mean that the company has this connection. Dirección General de Transporte Terrestre — Resolución de 26 de octubre de 2021.

For an internal workflow, we suggest reviewing the contract details, checking the vehicle assignment and giving an identified person responsibility for submission before the service. Linking the available submission information to the booking afterwards can help the office find it without rebuilding a shift from messages. This is a practical suggestion: it does not assume a particular receipt format or replace the register’s own operating instructions.

If the vehicle, time or destination changes, consult the current RVTC procedure for amendments or cancellations. The texts reviewed for this guide do not establish how those changes are processed. We cannot say that editing an internal booking updates a submission already sent, or describe an automatic correction process that the sources do not support. Make that distinction explicit when documenting the office workflow.

The infringements listed in Law 13/2021

Law 13/2021 added Article 140.39 to the Land Transport Organisation Act, or LOTT. Its very serious infringements include starting a service without the authorisation holder having communicated the details electronically to the DGTT register, in paragraph 39.2. The law made the application of that paragraph conditional on the register actually being operational. The issue is therefore not only whether a record contains the right information, but also when it is submitted. Boletín Oficial del Estado — Ley 13/2021.

The text also includes driving to find or collect customers without prior booking, starting services without the required advance booking, and driving without the required documentation and route sheet, or failing to show them to inspectors. We do not give fine amounts: the evidence used here does not support a financial penalties table. Nor do we infer a single nationwide minimum booking interval from that list of infringements. Boletín Oficial del Estado — Ley 13/2021.

Catalonia: a regional example to check separately

Catalonia’s Decree-law 9/2022 sets a minimum of 15 minutes between contracting and the actual service in Article 7.3. Article 7.6 allows local authorities to extend that interval. Article 7.4 also treats displaying available vehicles through geolocation before contracting as soliciting passengers and prohibits the practice. We do not apply those conditions to other autonomous communities or assume that the national submission settles every local question. Generalitat de Catalunya — Decreto-ley 9/2022.

Its first additional provision requires electronic communication of each service, before it begins, to a Generalitat register. Local authorities may create their own register or access the Generalitat’s. Article 11.o classifies failure to communicate as a very serious infringement. Before finalising a company procedure, check which register and territorial conditions apply to the operation. We do not assume that a single submission covers every administrative level or every location where a company works. Generalitat de Catalunya — Decreto-ley 9/2022.

Retention and the route sheet: unresolved points

The old wording of Article 24 of Order FOM/36/2008, introduced by Order FOM/2799/2015, required the route sheet and the lessor’s contract copy to be kept for one year from the date of the contract. That history does not establish a current one-year retention period for all RVTC information. Neither Royal Decree 785/2021 nor the 2021 resolution states a retention period in the texts reviewed for this guide. Ministerio de Fomento — Orden FOM/2799/2015. Ministerio de Transportes, Movilidad y Agenda Urbana — Real Decreto 785/2021.

Royal Decree 785/2021 removed Articles 23 and 24 of that order, with a transitional provision linked to the register becoming operational and the change to the infringement regime. However, LOTT Article 140.39.6 still refers to the route sheet. We do not resolve that relationship by inference: the present status of that documentation, and exactly what must be produced during a roadside inspection, remain points requiring confirmation. Ministerio de Transportes, Movilidad y Agenda Urbana — Real Decreto 785/2021. Boletín Oficial del Estado — Ley 13/2021.

We therefore recommend confirming the applicable retention period and required documentation with the competent authority before setting an archive or deletion policy. Retention in the public register and retention of the operator’s own documents are separate questions. This guide sets no period for either. It also does not claim that electronic submission removes every requirement to carry documentation in the vehicle, or that an internal booking export is sufficient roadside evidence.

Common office mistakes to avoid

• Treating a saved booking as a submitted service. Checking a CRM record does not demonstrate that the register received its details.
• Leaving submission until after the journey. The national rule places it before the start of each individual service.
• Adding passenger details just in case. The submission excludes service users’ data; copying the entire booking record is not a useful compliance check.
• Turning an old or regional rule into a current national rule. Catalonia’s 15-minute example and the historical one-year retention period have different contexts.

How we help with TransferCRM

With TransferCRM, we bring together booking and ride details, timestamps and the driver and vehicle assigned to each ride, alongside exports. This information supports the office in preparing and reviewing its work. We do not submit information to government registers, including the RVTC. A TransferCRM operational record or export is not an administrative submission and does not, by itself, establish regulatory compliance.

Frequently asked questions