What taxi companies should prepare for before December 2026

On 2 December 2026, the deadline to bring the EU Platform Work Directive into national law runs out. It's the first EU law written specifically for people who work through apps, and ride-hailing is one of the sectors it was written for.

If you run a taxi company in Belgium, this might sound like a problem for Uber and Bolt. Partly, it is. But many taxi companies sit right in the middle of that relationship: their drivers take platform rides, their cars carry platform work, and their records are what an inspector will ask to see.

Here's what the directive says, what Belgium already has in place, and what we'd get ready now.

This article is general information, not legal advice. For your own situation, talk to your social secretariat or an employment lawyer.

The short version

• The law: Directive (EU) 2024/2831 on improving working conditions in platform work, adopted on 23 October 2024.
• The deadline: member states must bring it into national law by 2 December 2026.
• Who it targets: digital labour platforms that organise work through automated systems, such as ride-hailing apps.
• What changes: a legal presumption of employment, the first EU rules on algorithmic management, and more reporting to authorities.
• Why taxi companies should care: companies that stand between a platform and a driver can count as intermediaries, and drivers working through them must get the same protection.

Who counts as a digital labour platform

The directive doesn't target every company that uses software. A digital labour platform organises work done by individuals, using automated monitoring or decision-making systems, as an essential part of its service. Matching a passenger with a driver and setting the price of the ride is the textbook example.

The directive itself distinguishes platforms from "traditional forms of ride hailing or transport service dispatch" (recital 19). A taxi company that takes bookings by phone and dispatches its own drivers is not, in principle, a digital labour platform.

That doesn't put taxi companies out of scope. Two parts of the directive reach them directly.

1. A presumption of employment

Under Article 5, the relationship between a platform and a person working through it is legally presumed to be employment when there are facts indicating direction and control. If the platform disagrees, it has to prove that the relationship isn't employment.

The presumption applies from 2 December 2026, including to contracts that are still running on that date. It doesn't apply retroactively.

Belgium is already ahead here, with two presumptions in force:

• For taxis and car-with-driver services, a royal decree of 29 October 2013 lists nine criteria. Among them: bearing no financial risk, having no say over prices, being guaranteed a fixed payment whatever the results, and driving a vehicle you don't own or lease. When more than half are met, the relationship is presumed to be employment.
• For digital platforms, since 1 January 2023, the law of 3 October 2022 presumes employment when at least three of eight criteria, or two of the last five, are met.

Courts are applying them. In June 2025, the Brussels Labour Court ruled that an Uber driver was an employee. It pointed out that the app measured acceptance rates and temporarily disconnected drivers who refused three rides in a row.

The directive will most likely push Belgium to align and strengthen these rules rather than start from zero.

2. Intermediaries

This is the part taxi companies should read twice.

Some drivers don't contract with the platform directly. They work through a company that holds the contract, the licence or the cars. The directive calls these companies intermediaries.

Article 3 requires member states to make sure that people working through intermediaries enjoy the same protection as those contracting with the platform directly, through mechanisms that include, where appropriate, joint and several liability. Article 17 also requires platforms to tell the authorities which intermediaries they work with.

How Belgium will define intermediaries and share liability will only be clear once the law is written. But if your drivers take platform rides through your company, expect your contracts, statuses and records to get more attention, not less.

3. Rules for algorithmic management

For the first time, EU law sets rules on how apps manage people. Platforms must:

• Stop processing certain data, such as a person's emotional or psychological state, private conversations, or data collected while they're not working (Article 7).
• Be transparent about the automated systems that affect work: how rides are assigned, how pay is set, and what can lead to an account being restricted (Article 9).
• Keep humans in charge. A decision to suspend or close an account must be taken by a person (Article 10).
• Explain and review decisions. Drivers can ask for an explanation and a human review, and must get an answer within two weeks (Article 11).

Several of these rights apply to self-employed drivers too, not only to employees.

4. Reporting to the authorities

Under Article 17, platforms must make information available to the authorities and to workers' representatives, updated at least every six months: how many people work through them and under which status, their general terms and conditions, average hours and income (on request), and the intermediaries they work with.

In practice, the authorities will see the platform's side of the story. Taxi companies should be able to show the same reality from theirs.

Where Belgium stands

Belgium already has a platform presumption, so part of the work is done. At the time of writing, we couldn't find a published Belgian bill transposing the rest of the directive, including algorithmic management and reporting. Several member states are running late, so the final rules could arrive close to the deadline, or after it.

Waiting for the final text isn't a plan. Most of what you need to prepare doesn't depend on its details.

What to prepare now

Map how each driver works. For every driver, write down whether they're an employee or self-employed, which licence they drive under, whose car they use, and which platforms they take rides from. It's the first thing a labour inspector or a court will look at.

Check self-employed statuses against the criteria. Go through the nine taxi criteria for each self-employed driver. If more than half apply, you already have a risk today, directive or not.

Review your platform contracts. Who is the contracting party for each driver? What does the contract say about responsibility, data and account suspensions? If you're an intermediary, find out now rather than in December.

Keep complete records for every shift. Hours worked, rides, revenue by payment source, expenses and what each driver was paid. Average hours and income per person are exactly what platforms will have to report. You should have your own version of those numbers.

Make pay traceable. For every driver payment, you should be able to show how the amount was calculated, from the ride to the transfer. Disputes and inspections both start there.

Talk to your social secretariat. Ask what the Belgian transposition could change for your contracts, and when.

How Tomcabs helps

Tomcabs doesn't decide anyone's employment status. It gives you the records you need to answer the questions above.

Every shift is recorded with its start and end times, kilometres, rides and payment sources, including platform rides. Driver payments show how each amount was calculated. Documents such as licences and insurance certificates are stored with your team, with reminders before they expire.

When the rules change, clean records are the part you won't have to rebuild.

Sources

• Directive (EU) 2024/2831 on improving working conditions in platform work, EUR-Lex
• Presumption in the transport sector: taxis and car-with-driver services, Commission Relations de travail
• Law of 3 October 2022 on various labour provisions
• Brussels Labour Court rules that an Uber driver is an employee, Claeys & Engels
• Article 3 in the Platform Work Directive on intermediaries, Astrid Sanders, 2025