The plans to introduce the new Central Taxi Database (CDT) to replace the current Taxi On-Board Computer (BCT) have raised many questions among taxi entrepreneurs and drivers about the consequences for regulatory pressure.
The Advisory Board for Regulatory Burden Assessment (ATR) has critically uttered about the lack of a clear picture of these regulatory burden consequences in an advice to the State Secretary of Infrastructure and Water Management, Mr. Ch.A. Jansen. The ATR emphasizes that the costs for the purchase of the new system and the transition problems must be mapped out before the introduction can finally take place.
no watertight solution
In the current situation, taxi entrepreneurs are required to register the working and rest times of drivers using the On-Board Computer Taxi, a system that has been in use since 2016. This BCT registers data that is stored by the entrepreneur himself and must be made available to the Inspectorate for the Environment and Transport (ILT) on request. However, the BCT has not proven to be a watertight solution: technical malfunctions, regular software updates and the replacement of system cards are a costly burden for entrepreneurs. In addition, the ILT cannot read the data remotely, which means that enforcement remains time-consuming and taxi drivers must be physically present during checks. The objectives of the BCT, such as more efficient enforcement and lower administrative burdens, are therefore not fully achieved.
The new CDT, which will be mandatory as of 1 January 2028, should solve these bottlenecks according to the ministry. The CDT is a central database that will be managed by the Inspectorate and collects the data of entrepreneurs and drivers in a structured and uniform manner. This replaces the obligation for taxi entrepreneurs to store and manage data themselves with a delivery obligation. This means that entrepreneurs must transfer the data to the CDT via an IT tool, such as an app or a separate device, that meets specific technical requirements.
However, this change in the system brings new challenges and costs. The ATR emphasizes that while entrepreneurs may realize savings through the elimination of maintenance and update costs of the BCT, new expenses are now coming, such as the purchase of the IT resourcel and the monthly subscription fee to the IT supplier. For taxis that have recently been equipped with a BCT, the transition may also mean an accelerated depreciation of the investment in the current system, which may result in additional costs for entrepreneurs.
phase out
In the underlying regulatory burden paragraph of the proposal, the ministry acknowledges this change in costs, but the ATR notes that the calculation of the net regulatory burden costs is not complete. For example, the reduction in regulatory burden, such as the abolition of the retention obligation and the phasing out of system cards, has not been calculated accurately. The ATR therefore advises that the government thoroughly maps out the cost structure according to the applicable government-wide methodology. Without a clear insight into the financial impact for entrepreneurs, it is not responsible to make the decision final, according to the ATR.
The ATR concludes that the proposed introduction of the CDT should only be finalised once the above-mentioned advice and cost studies have been fully implemented and the potential regulatory burden has been clearly identified.
Given the technical complexity and cost considerations, the government would be wise to implement the scheme carefully and in phases, in order to give taxi companies sufficient time and space for a smooth transition.
The proposed changes also have an impact on the practical workability of the new system for taxi entrepreneurs and drivers. Various parties, including industry organizations and drivers, have been involved in the development of the CDT. Pilots with the CDT have now been successfully completed and have yielded positive responses. This indicates that the new system is in principle workable for the target group, although it remains questionable whether these positive results will be representative for the sector as a whole.
research
According to the ATR, there is a need for detailed research into the ease of use and costs of various IT resources, such as the costs of apps and devices that meet the requirements of the CDT. The expectation that entrepreneurs can develop a suitable IT resource themselves, as stated in the advice, also seems less feasible in practice due to the technical requirements that this resource must meet.
The new regulation offers entrepreneurs and drivers a choice in the transitional phase: until 1 January 2028 they can still choose between the BCT and the CDT. This option should offer taxi entrepreneurs some flexibility, so that they can switch gradually. After that date, however, the CDT will become mandatory, and the current BCT will be phased out completely. With this, the government is taking a step in the digitalisation of the sector, but the road to this will be a challenge for many entrepreneurs, both organisationally and financially.
