Picking up guests at the airport in the hotel car: do you need a licence? Can you charge? (2026)

Updated: 10 November 2026

Many small hotels pick up their guests at the airport or the station in their own car or van. It is a good service, but carrying people has rules. We read Spain's Land Transport Act 16/1987 (BOE-A-1987-17803), the Compulsory Passenger Insurance, the Andalusian urban transport act, the Portuguese coach decree, the Italian NCC act, the Codice della strada and a reply from the Greek ministry (links at the end). Where we could not confirm something we say so. This is not legal advice: check with your adviser.

The essentials

With your own vehicle and staff, the transfer must be an add-on to the stay, not a separate business.
In Spain you cannot sell or invoice it separately.
A passenger car needs no authorisation in Spain; a bus does.
If you want to charge for the transfer, book a licensed taxi, private-hire (VTC) or transport company.
Check with your insurer that the policy covers this use of the vehicle.

Spain: it is ancillary private transport

Land Transport Act 16/1987 (BOE-A-1987-17803), arts. 62, 100 and 102:

It is transport run by a company whose business is not transport, as an add-on to its main activity.
Passengers must be the company's workers or people who come to its premises. The act does not name guests: including them here is our reading.
The origin or destination must be a place of your business, such as the hotel.
Vehicles and drivers must be part of your business (owned or rented by it, and a driver on your staff).

Spain: do you need authorisation?

Same act, art. 103:

As a rule, ancillary private transport needs authorisation.
Exception: «passenger cars» (vehículos de turismo) do not (except medical transport).
A bus does. A van: check its category in the registration papers; we have not confirmed every case.
Being exempt from authorisation does not exempt you from the other requirements.

Spain: can you charge?

Not separately: art. 102 says this transport «may not be contracted or invoiced independently».
If you do not meet the conditions, art. 102.3 puts it under the public transport rules.
Running public transport without the required licence is a very serious offence (art. 140.1). We did not read the fine amounts.
If you want to charge, hire a licensed taxi driver, VTC or coach company.

Andalusia

Andalusian Act 2/2003 on urban and metropolitan transport covers only public transport. We found no specific Andalusian rule on guest transfers: the national act applies.

Insurance

Royal Decree 1575/1989, Compulsory Passenger Insurance (Seguro Obligatorio de Viajeros):

It covers users of public collective transport.
It excludes vehicles with fewer than nine seats.
In private vehicles it applies only if the transport is public.
We did not read the compulsory motor insurance rules: ask your insurer in writing to confirm the policy covers carrying guests.

Portugal

Decree-Law 3/2001 (original text, on the AMT website; later amendments not checked), for vehicles with more than nine seats including the driver:

Own-account transport: no profit or commercial aim, and only as an ancillary activity.
Vehicles owned, leased or rented for more than a year, with a driver on your staff.
It needs a certificate from the DGTT (the body named in the text), valid for up to five years.
Without it, a fine of EUR 250 to 1,250.
Cars with up to nine seats: we have not confirmed the rule.

Italy

Act 21/1992 and Codice della strada, art. 83:

NCC (hire with driver) is a non-scheduled public service; municipalities grant the authorisation through a public call.
If you book an NCC or a taxi, a licensed operator does the transport.
For your own bus or a vehicle for the specific transport of people, the registration for own use (uso proprio) is issued only to businesses and bodies for needs linked to their activity, after a check by the transport administration (unofficial copy of art. 83).
For an ordinary car, and whether you can charge: not confirmed.

Greece

2016 reply from the Ministry of Infrastructure and Transport (Α 30108/2000, Taxheaven copy; later changes not checked):

Tourist accommodation may carry its guests free of charge (άνευ κομίστρου) in cars it owns or leases, between airport, port or station and the property (Law 4252/2014).
The vehicles must carry the markings set by joint decision Α 48936/4664/2012.
With a private-use bus: only between arrival or departure points and the hotel, or the nearest town.
If you want to charge, you can hire taxis or car-with-driver companies at an agreed price.
Carrying passengers for a fare in a private car is banned: at least six months in prison and a fine of at least EUR 3,000.

Transfer plus room: a package?

If you sell the transfer together with the room as a bundle, it may be a package travel contract, with its own obligations. See our guide: iquota.io/hotel-excursion-transfer-package-travel-directive-2026.

How iQuota helps

We publish your property in AI assistants with direct booking, payment at the property and no commission, showing your real services, such as transfers.

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See the Founding Hotels programme

Frequently asked questions

Do I need a licence to pick up guests in the hotel car?

In Spain, with your own passenger car and a driver on your staff, no authorisation is needed (Act 16/1987, art. 103). With a bus, it is.

Can I charge for the transfer?

In Spain, not separately: ancillary private transport cannot be contracted or invoiced on its own. If you charge, it is public transport and needs a licence.

What about Greece?

According to the ministry, properties may carry guests free of charge in cars they own or lease, with markings. Charging in a private car is banned.

Sources

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