 
  Final impact assessment  1 (35)  
Date  Ref/Designation  
11 June  2019  TSF 2018 -134 
Administrator  
Jenny Bragg  
Roads and railways  
Commercial traffic  
Commercial traffic regulations  
 
 
 TS2503, v03.00, 2018 -04-10 
1. ------IND- 2019 0299 S -- EN- ------ 20190710 --- --- 
IMPACT 
Final impact assessment for the regulations on 
licensable booking centres’ operations and 
equipment as well as regulations  on special 
equipment for taxis  
An in -depth analysis of privacy risks has been completed in accordance with 
what the Swedish Data Protection Authority requested in its response (DI -
2019 -4626). The additions that have been made are included in the annex 
and underlined.  
The Swedish Transport Agency’s proposal:  
The Swedish Transport Agency proposes new regulations and general 
recommendations due to Parliament 's decision on a new category of taxi 
traffic.  
The proposed regulations comprise the requirements covering  
 –the licensable booking centres’ operations and what information shall be 
collected, stored and provided by the booking centre,  
 – the booking centre’s technical equipment and  
 – the special equipment for taxis.  
Subsequently, significant changes will need to be made in the regulations  
 – TSFS  2013:41 on taxi traffic,  
 – TSFS  2016:46 on reporting centres for taxi traffic,  
 – TSFS  2016:47 on technical equipment at reporting centres for taxi traffic 
and 
 – TSFS  2016:48 on reporting of information reg arding the inspection of 
taximeter equipment.  
The purpose of the proposal is to ensure that the information the Swedish 
Tax Agency needs to perform its tax inspections is reliable and that it can be 
collected, stored and provided securely by the new licens able booking 
centres. It is important that the tax inspections for the new category of taxi 
traffic will be equivalent to the tax inspections performed for taxi companies 
whose vehicles are equipped with a taximeter.    
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A. General  
Parliament  has decided to intro duce a new category of taxi traffic.1 As a 
result of the decision, the exemption from the requirement to have a 
taximeter in a taxi vehicle is revoked. In place of the exception, individuals 
who have been granted the exemption must choose between acquiring  a 
taximeter or entering into the new category of taxi traffic. With the creation 
of the new category, taxi vehicles that are not equipped with taximeters 
must be equipped with special equipment for taxis and taxi companies must 
connect the vehicles to a l icensable booking centre.  
Licensable booking centres shall receive and allocate driving assignments to 
those holders of taxi traffic licen ces who have vehicles affiliated with the 
centre. The booking centre shall have technical equipment that is able to 
collect, store and provide the information that the Swedish Tax Agency 
needs to perform tax inspection of taxi drivers and taxi companies in the 
new category.  
Those who select the new category will only be permitted to perform 
driving assignments that are pr e-ordered at a fixed price. Before the journey 
commences, the booking centre is obliged to provide evidence of the price 
to the purchaser for the agreed journey or the price for the time the vehicle 
shall remain available to the purchaser. The payment must  be made to the 
booking centre which has allocated the driving assignment and must not 
take place through the taxi driver  or taxi licence holder's involvement.  
The reason for the change in legislation is that, since the introduction of 
reporting centres2, the Swedish Tax Agency has been given a better 
opportunity to conduct tax inspections of taxi companies whose vehicles are 
equipped with a taximeter. As a result, the disparity in the agency’s 
opportunity to perform tax inspection for vehicles with taximet ers versus 
those that do not have the devices has become greater. The introduction of 
the new category of taxi traffic is intended to eliminate this disparity and 
ensure that the agency’s inspection options in the new category are 
equivalent to those for t axis with a taximeter.3 
                                                
1 Prop. 2017/18:239 A new category of taxi traffic, adopted 14  June 2018.  
Act (2018:1126) amending the Act (2014:1020) on reporting centres for taxi traffic. 
Act (2018:1125) amending the Taxi Traffic Act  (2012:211).  
Act (2018:1124) amending the Vehicle Act  (2002:574).  
Act (2018:1123) amending the Road Traffic Register Act  (2001:558).  
2 Prop. 2013/14:223, Re porting centres for taxis.  
3 Prop. 2017/18:239, pp.  36 and 90.    
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1. What is the problem or reason for the regulation?  
The first reason for the proposed regulations is that no current law or 
ordinance stipulates what information the licensable booking centres shall 
collect, store and provide. It is a lso unclear how the information should be 
collected, stored and provided. Therefore, the regulations need to stipulate 
what information is needed in order for a tax inspection to be performed. In 
order to ensure the reliability of the information, the regu lations also need to 
ensure that the booking centres collect, store and provide the information 
accurately and securely so that it is able to be used during a tax inspection.  
The second reason is that taxi vehicles that do not have taximeter equipment 
must  be equipped with what is referred to as ‘special equipment’. The 
special equipment must be in the taxi vehicle itself and register information 
that corresponds with the vehicle’s odometer and times. The Swedish Tax 
Agency needs this information to be able  to review the taxi vehicle’s use. 
The detailed technical requirements will be established in the government 
regulations.4 
Therefore, our regulations need to specify which functions the special 
equipment for taxi vehicles needs to have in order for the lic ensable booking 
centre to utilise the special equipment to securely collect information from 
the vehicle. In order to ensure that the information is reliable, the 
requirements also need to contain provisions defining how the special 
equipment for taxis sha ll be used and how its functionality shall be verified.  
2. What is to be achieved?  
The purpose of the proposed requirements is to ensure that the information 
the Swedish Tax Agency needs to perform its tax inspections can be 
securely collected, stored and pro vided via the booking centres using the 
technical equipment and special equipment in the taxi, and that the 
information is reliable. Any movement of information from one device to 
another must be subject to requirements for data integrity requirements and 
secure data transfer. With this we mean that information that needs to be 
protected may not be altered during the time it is collected, stored or 
provided.  
It is important that the regulations we ultimately issue both enable the 
satisfactory performance of  tax inspections and leave room for a variety of 
technical solutions. Therefore, the proposed regulations have a clear focus 
on reliability and information security and, as much as possible, are 
technology -neutral with functional requirements.  
                                                
4 Prop. 2017/18:239 pp.  49–50.   
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3. What are the  alternative solutions?  
3.1 Effects if nothing is done?  
If the new regulations do not stipulate what information shall be collected, 
stored and provided, the Swedish Tax Agency may not receive adequate 
documentation.  
If the required functions for the technical  and special equipment are not 
clearly stipulated, the equipment may not have the capability to collect, 
store and provide information to the Swedish Tax Agency. If, in the event of 
bankruptcy, a booking centre is unable to transfer already delivered 
infor mation to another booking centre, the Swedish Tax Agency will not be 
able to obtain control material for those taxi firms which were connected to 
the bankrupted centre. In addition, there is the issue of ensuring the 
information’s security if no security r equirements can be stipulated. This is 
in light of the fact that it is as insufficient to certify the technical equipment 
under the overall provisions of the Act and Ordinance as it is insufficient to 
not require certification of the special equipment.  
In summary, the purpose in creating the new category of taxi traffic will not 
be achieved if the Swedish Tax Agency is unable to carry out tax 
inspections for the companies in the new taxi traffic category that are 
equivalent to the inspections they perform o n companies whose taxi 
vehicles are equipped with taximeters.  
3.2 Options that do not involve regulation  
The decision to introduce special equipment into taxi vehicles and 
requirements for linking the vehicles to licensable booking centres as an 
alternative to  taximeters and requirements for linking these to reporting 
centres has been made through legislation. The provisions need to be 
complemented with requirements specifying what information shall be 
collected, stored and provided, requirements for the techni cal and the 
special equipment and requirements for the booking centre in order for the 
intended purpose in creating the new category to be achieved. In light of 
this, and of what has been stated in Section  3.1, the Swedish Transport 
Agency cannot see any a lternative which does not involve regulation.    
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3.3 Regulatory options  
A. Regulations on booking centres for taxi traffic  
Operational requirements regarding what information shall be collected, 
stored and provided by the booking centre  
Option  1 – The Swedish Transp ort Agency's proposal  
In our proposal for new regulations, we have considered the information 
that the Swedish Tax Agency indicates that it needs to be able to carry out 
tax inspections. The personal information (direct and indirect) that the 
Swedish Tax A gency needs for its tax inspection primarily consists of 
information about which driver has accepted a driving assignment, which 
vehicle has been used and to which licence holder the respective vehicle is 
registered for taxi traffic.  
However, there is othe r information that the Swedish Tax Agency does not 
need for its tax inspections, and this information shall not be collected and 
stored by the booking centre’s technical equipment. For example, the 
Swedish Tax Agency does not need information regarding who  ordered or 
took the journey. Therefore, names, account numbers and other information 
that can be directly or indirectly linked to a purchaser or rider shall not be 
collected and stored. Refer to the annex for further information regarding 
other personal i nformation.  
When the Swedish Tax Agency determines whether the income, expenses 
and social fees reported by the taxi traffic licence holder covers all taxi 
drivers that the licence holder has used, the agency needs to access 
information on the driver's ide ntity. Each driver has a six -digit driver’s code 
on his/her taxi driver’s licence that the Swedish Transport Agency assigns to 
the driver when the taxi driver’s licence is issued. When performing a tax 
inspection, the Swedish Tax Agency may obtain informat ion from the 
Swedish Transport Agency regarding which driver has a respective driver’s 
code, since this information is registered in the Road Traffic Register. 
Therefore, there is no need for the booking centre to collect and store any 
personal information  on the driver beyond the driver’s code.5 This is also 
consistent with the way information is collected for taxi drivers who drive 
vehicles equipped with taximeter equipment. At the start of the driving 
session, the drivers shall register their driver code in the taximeter 
equipment.6 
                                                
5 Prop. 2017/18:239 s.  42. 
6 Chapter  3, § 3 of the Swedish Transport Agency's regulations (TSFS  2013:41) on taxi 
traffic.    
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Since taxi drivers in the new category of traffic will not be able to register 
information in the special equipment for taxi vehicles, the booking centre's 
technical equipment shall collect information on the taxi driver’s code 
instead of via one of its connected sys tems. Our recommendation is that the 
information be registered electronically, but this can be done in a number of 
different ways using a variety of technical solutions. Therefore, we have 
opted not to propose specific regulations regarding how registratio n shall 
take place.  
Option  2 
We have considered establishing requirements that the taxi driver must 
identify himself/herself electronically through an e -identification process 
that is linked to the driver's personal identity number and in this way, the 
booking centre would collect information about the driver's identity. The 
purpose of such a requirement would be partly to increase the level of 
reliability of information on the driver’s identity by more clearly linking this 
information to an individual, and partly to make it less likely that inaccurate 
information is recorded, either intentionally or accidentally.  
Considering the need to protect the taxi driver’s privacy and given the fact 
that it is possible to identify drivers using the driver’s code, w e do not 
believe it is necessary to collect any additional information on the drivers. 
Therefore, we will not perform a further evaluation of this issue.  
B. Regulations concerning technical equipment at taxi traffic 
booking centres  
Certification of booking ce ntres’ technical equipment is a requirement under 
the Ordinance on reporting centres and booking centres for taxi traffic. 
However, the regulations contain requirements on what the certification 
shall cover and what requirements need to be met. Such a requ irement 
applies to information security management systems.  
Management systems for information security  
Pursuant to §  9 in Act  (2014:1020) on reporting centres and booking centres 
for taxi traffic, information shall be collected, stored and provided under 
conditions that are intended to maintain the security of information. 
Therefore, the main question is not whether the regulations need to include 
requirements for information security management systems, it is the level 
that these requirements should be se t at. 
Option  1 
One alternative is to require the manufacturer to provide an information 
security management system in accordance with the respective standard, for 
example ISO/IEC  27001.    
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Option  2 – The Swedish Transport Agency's proposal  
Another alternative  is to require that manufacturers have a documented 
information security management system but without requiring the 
manufacturer to follow a certain standard. There will instead be provisions 
in the regulations that stipulate which requirements shall be m et in order for 
the equipment to function in a satisfactory manner.  
C. Regulations and general recommendations for special equipment 
in taxi vehicles  
In order to be able to review the historic use of a taxi, there needs to be 
technical equipment in the taxi t hat records the route, mileage and time.7 
Chapter  2 b, § 1 in the Taxi Traffic Act  (2012:211) refers to such equipment 
as ‘special equipment for taxis’.  
Collection of information on the total or cumulative route mileage  
The special equipment for taxis needs to either collect information on the 
total route distance the vehicle travels or the cumulative route mileage the 
vehicle travels from the point in time the equipment was installed in the 
vehicle. The information shall be given in kilometres and coll ected by the 
booking centre’s technical equipment which retrieves the information from 
the special equipment.  
The purpose for collecting the total route mileage or the cumulative route 
mileage is to improve the ability of the Swedish Tax Agency to perform tax 
inspections. By comparing information on route mileage at the start and end 
of a driving assignment, the distance the vehicle has travelled during the 
driving assignment can be calculated. This information can be compared 
with information for the estim ated route mileage that the booking centre 
used for its price calculation. The information can also be used to assess 
how reasonable a completed taxi route is with a rider in the vehicle 
compared to the amount earned and the degree to which the vehicle was  
used for private travel.  
There are more potential options that may be used to collect information on 
the total and cumulative route mileage.  
                                                
7 Prop. 2017/18:239, p.  49.   
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Option  1 
This option allows the use of GNSS technology8 to calculate the cumulative 
route mileage. This is done by  calculating where the vehicle is at the start 
and end of each driving assignment.  
Option  2 – The Swedish Transport Agency's proposal  
The second option is to use standardised signals from the vehicle or signals 
that come via the vehicle to collect informat ion on the total or cumulative 
route mileage. This can be done in a number of ways. Some examples are 
given below, but this should not be seen as an exhaustive list.  
Odometer status via standardised signals  
The use of standardised signals from a vehicle’s odometer would mean that 
the information is retrieved directly from the vehicle and that the 
functionality of the technology is not dependent on an external system.  
Mileage calculation using standardised speed and time  
Another alternative is to calculate t he route using standardised signals for 
the speed the vehicle has travelled and the time that has elapsed between the 
start and end of the driving assignment.  
Measuring a route using an independent measuring system  
Another example of how signals coming fro m the vehicle can be used is that 
the cumulative route mileage can be measured using wheel sensors, similar 
to the way a taxi meter measures route distances.  
Communication between the special equipment in taxis and the booking 
centre  
One precondition for the booking centre’s technical equipment to be able to 
collect information from the special equipment is that the equipment is 
compatible, i.e. that they both speak the same ‘language’. A licence holder 
who would like to connect to a booking centre would t herefore need to have 
special equipment that can communicate with the technical equipment at the 
booking centre. This communication can be regulated with specifics, in 
detail, or only through a functional requirement relating to security.  
                                                
8 Global Navigation Satellite Systems – the common name for the satellite systems are used 
for global navigation and positioning. Examples of these systems include GPS and 
GLONASS. https://swepos.lantmateriet.se/kurserochinfo/vadargnss/vadargnss.aspx    
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Option  1 
This opt ion will require us to develop detailed regulations for 
communication between the special equipment and the booking centre’s 
technical equipment.  
Option  2 – The Swedish Transport Agency's proposal  
Another option will require us to develop regulations for communication 
between the special equipment and the booking centre’s technical 
equipment to ensure that it is done securely, but without specifying exactly 
how this shall be done.  
Manufacturer declaration or certification of special equipment for taxis  
The question of how the special equipment will be certified, or whether the 
equipment’s compliance with stipulations in the proposed requirements 
shall be assessed in some other way, is primarily a matter of verifying the 
equipment's built -in security functio ns and quality, but also a matter of 
costs.  
Option  1 
This option would require the manufacturer itself to certify compliance with 
the stipulations in the proposed regulations through what is known as a 
manufacturer’s declaration.  
Option  2 – The Swedish Tra nsport Agency's proposal  
Another option is to require certification, which would mean that a third 
party, i.e. an independent certification body, would assess whether the 
stipulated requirements are met. How certification shall be regulated 
through ISO/IEC  17065.9 Product certification, which is an important issue 
for the special equipment, would mean that a certification body would 
review technical documentation and see that tests are performed to ensure 
that the requirements of the regulations are met.  
Inspection of special equipment for taxis  
The Swedish Transport Agency has considered whether it is necessary to 
introduce inspection requirements for the special equipment and, if so, what 
would need to be verified. On the one hand, the government bill to c reate a 
new category of taxi traffic is characterised by the theme that authorities 
need to have an equivalent opportunity to perform inspections of the new 
category of taxi traffic as they do for taxis equipped with taximeter 
                                                
9 Conf ormity assessment – Requirements for bodies that certify products, processes and 
services (ISO/IEC  17065:2012).    
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equipment. On the other hand,  the special equipment will perform fewer 
tasks than the taximeter equipment and does not need to have the same 
requirements for accuracy, since the equipment will not be a measuring 
instrument that will calculate a price.  
Option  1 
This option would not st ipulate the introduction of a requirement for the 
inspection of the special equipment.  
Option  2 – The Swedish Transport Agency's proposal  
Another option is to establish requirements for the inspection of the special 
equipment similar to the requirements th at apply to taximeter equipment. 
Inspection shall occur after mounting and installation in order to ensure that 
the equipment is installed correctly and functions in accordance with the 
prescribed requirements. Regular inspection would then be performed af ter 
the initial inspection, no later than one year from the date of installation or 
from the most recent inspection.  
4. Who will be affected?  
The proposed regulations primarily affect the taxi licence holders that 
currently have taxis that are granted exempti ons from the requirement for 
taximeter equipment. Those affected will need to choose whether to equip 
their vehicles with taximeters or with special equipment for taxis. Those 
who choose to enter into the new category and acquire special equipment 
are affe cted by the proposed regulations, particularly because the 
requirements in the regulations will affect the cost of purchasing special 
equipment and due to the requirement for connection to a licensable 
booking centre.  
Additionally, those wishing to conduct  operations as a licensable booking 
centre and those wishing to manufacture technical equipment for booking 
centres and special equipment for taxi vehicles are affected.  
There are also other actors who are affected by the proposed regulation to a 
lesser ex tent, see Sections  5.2, 5.3 and 12.  
5. What is the impact of the regulation?  
5.1 Companies  
( ) The regulation is not deemed  to significantly impact the working conditions, 
competitiveness or other conditions of companies. All consequences for companies 
are therefore described under 5.1.  
 
(X) The regulation is deemed to significantly impact the working conditions, 
competitiveness or other conditions of companies. The impact assessment   
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therefore contains no description under 5.1.; instead, all consequences for 
companies are described in Section  C. 
5.2 Citizens  
The new refor m category may result in taxi firms needing to cover new 
costs, for example, for connection to a booking centre and the purchase of 
special equipment for taxi vehicles. In the long term, this may have an 
impact on the prices of taxi journeys. This potentia l impact is a result of the 
Swedish Parliament's decision to introduce a new category of taxi traffic. 
The regulations being proposed here may also affect prices as these affect 
consumers, since the proposed requirements to be set for the booking 
centre’s technical equipment and on the special equipment for taxis will 
affect manufacturing costs of this equipment. This, in turn, affects expenses 
for order centres and taxi companies. At the present moment, however, it is 
difficult to estimate to what extent t he prices for taxi journeys in the new 
category will be affected by the requirements in the proposed regulations.  
5.3 The state, region or county councils and municipalities  
The introduction of a new category for taxi traffic primarily concerns the 
Swedish Tra nsport Agency through the requirements that relate to the 
provisions in the legislation.10 The requirements in the regulations have less 
of an impact on the need for training on evaluating the documentation that 
must accompany an application for a licence t o operate a booking centre, for 
example.  
The Swedish Tax Agency is also primarily affected by the requirements that 
relate to the provisions in the legislation.11 The Swedish Transport Agency’s 
assessment is that the proposed regulations primarily relate to  the 
development of IT functions that the Swedish Tax Agency needs for 
processing the information they will request from booking centres. These 
costs are already covered under development costs.  
Swedac shall accredit the certification bodies that will cert ify the booking 
centres’ technical equipment pursuant to the provisions of the ordinance. 
                                                
10 The authority's development costs for introducing the new regulation have been revised 
since the issue of Prop.  2017/18:239 and are now calcul ated at SEK  5.7 million. The 
execution of the necessary tasks that will be added after their introduction is expected to 
amount to 1.5  FTEs. Subsequent annual administration costs, which are difficult to 
calculate, will also be added at an estimated SEK  200 000 per year.  
11 In the Swedish Tax Agency’s submitted response to the inquiry – taxi and ride -sharing, 
today, tomorrow and the day after tomorrow (SOU  2016:86), the agency stated that they 
calculated their costs for the development of IT systems, regulat ory development, 
information and education initiatives to a total  
of SEK  4 million, while the annual cost after completion of the development work was 
estimated at SEK  400 000 per year.    
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Based on the number of actors who have expressed interest in performing 
certification of reporting centres’ technical equipment, we believe that a 
number of certifica tion bodies will be interested in certifying the booking 
centres’ technical equipment, and therefore, the requirement will not entail a 
significant expansion of Swedac's activities.  
However, as it pertains to certification of the special equipment for taxi s, 
this is a requirement that is stipulated in our proposed regulations. For 
Swedac’s part, this means they will need to accredit the certification bodies 
that will certify the special equipment. Since the regulations concern brand 
new equipment that is no t currently available on the market, It is difficult to 
determine how many certification bodies will apply for accreditation for the 
certification of the special equipment. Our assessment is that few 
applications will be submitted, based on the fact that, at least initially, there 
is a limited market for the equipment, since it concerns equipment for only a 
couple thousand vehicles.  
Swedac will need to develop an inspection system. Swedac’s work will 
include the preparation of proposals for a new inspection  report and 
information initiatives for existing and prospective accredited bodies in 
relation to creating opportunities and conditions for expanding accreditation. 
Additionally, a portion of Swedac’s staff, likely the staff members who 
already have the au thority to oversee inspection bodies for taximeters, shall 
be trained with regard to the special equipment’s functions and how it will 
be inspected and sealed. This training should preferably be carried out by 
one of the parties who manufactures the specia l equipment, and Swedac 
estimates that the training effort will affect eight persons. In total, the work 
on a new inspection system is expected to amount to at least 60  hours.  
The regulations also set a requirement that Swedac issue seal numbers to the 
inspection bodies for their sealing tools. Swedac assesses that all of these 
measures can be carried out within the existing fee structure.  
Provisions in the new legislation stipulate that the police shall inspect the 
special equipment for taxis. Since this i nvolves a new type of equipment, 
the police will need to establish new procedures for how the equipment will 
be inspected. The scope of these procedures may be affected by the 
proposed regulations, since the regulations leave some room for the special 
equipment to be designed in different ways.  
5.4 Externalities  
In the opinion of the Swedish Transport Agency, the proposed regulations 
will have no impact on society in general.    
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6. What is the impact of the considered alternatives to the 
regulations and why are the r egulations considered to 
be the best option?  
Regulations on booking centres’ technical equipment  
Management systems for information security  
Information that relates to a booking centre’s operations shall be collected, 
stored and provided under conditions that are intended to maintain the 
security of the information.  
Option  1 
This alternative requires the manufacturer to have an information security 
management that meets the requirements under a particular standard. Of 
course, such a requirement will entail  a more consistent and likely even 
higher level of security in the equipment, but It also entails increased costs 
for manufacturers since their operations will need to undergo security 
certification.  
Option  2 – The Swedish Transport Agency's proposal  
We be lieve that Option  2 is more appropriate for the intended purpose, as it 
does not require the manufacturer to comply with a specific information 
security standard. Instead, the regulations contain requirements that must be 
met in order for the equipment to collect, store and provide the information 
in a satisfactory and safe manner. Therefore, there will be several ways 
these requirements may be met. It is worth noting that we have given the 
same consideration with regard to the booking centre’s operations a nd 
manufacturers of special equipment for taxis.  
Regulations and general recommendations for special equipment in taxi 
vehicles  
Collection of information on the total or cumulative route mileage  
It is important for the completion of tax inspections that information relating 
to how far a taxi has travelled is reliable.  
Option  1 
This option entails using GNSS technology to collect vehicle route mileage 
information. This option does have an inherent problem, as GNSS 
technology is not used to calculate route distances but to calculate positions. 
Positions would then need to be translated into route distances, and as far as 
we have been able to determine, there is no such tool available to make this 
translation. Nor does GNSS technology offer an easy way to get  reliable   
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data on the vehicle's total distance travelled, information that is important 
for the Swedish Tax Agency's inspections.  
Another consequence of selecting Option  1 is that although positioning 
technology can be used to calculate route distances, th e positioning 
information it provided is not entirely reliable. This is due to the fact that 
there are so -called ‘holes’ or shadow zones where no signals from the 
satellite systems reach. It is also possible to manipulate GNSS data by 
interfering with the signals or to manipulate the data so that it points to other 
positions. Although there is technology available which is intended to 
protect GNSS data from manipulation, establishing a requirement for such 
protective technology would be costly and would not  solve the problem of 
shadow zones where the signals simply do not reach.  
The Swedish Transport Agency and the Swedish Tax Agency assert that 
GNSS technology should not be used since there are too many possible 
sources of error which would mean that inform ation about the vehicle's 
route mileage would not be as reliable as it needs to be for the Swedish Tax 
Agency's inspections.  
Option  2 – The Swedish Transport Agency's proposal  
It is the Swedish Transport Agency and the Swedish Tax Agency’s 
assessment that Option  2 provides a more reliable basis for the Swedish Tax 
Agency’s inspection activities since the total or accumulated route mileage 
information comes from or via the vehicle and not from an external system. 
Although it is also possible to manipulate su ch information, for example, if 
the vehicle’s odometer reading is rolled back on one occasion, but the 
odometer reading in the next reading will be smaller in comparison to the 
previous reading. Changes such as these can be detected by comparing the 
total route mileage collected from standardised signals and the vehicle's 
odometer reading which is read at vehicle inspection and at the inspection of 
the special equipment.  
And the fact that there are several different ways the information can be 
retrieved fro m or via the vehicle can also offer advantages. Depending on 
when and by whom the vehicle was manufactured, different technical 
solutions may be needed.  
In light of the above, the Swedish Transport Agency supports Option  2. 
Communication between the specia l equipment and the booking centre  
It would be preferable if the special equipment functioned for more than one 
booking centre. The reason for this is that licence holders should have the 
technical capability to connect to several booking centres so they c an choose 
the driving assignments that suit them best and to maximise the use of the   
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taxis. Licence holders should not have to purchase more than one special 
equipment unit per vehicle.  
Option  1 
This option will require us to develop highly detailed regula tions for how 
communication shall be used in order to ensure that all special equipment 
and all of the booking centres’ technical equipment will be compatible even 
if they are manufactured by different actors. This option will require us to 
stipulate which  communication patterns, protocols and security solutions the 
different equipment uses to communicate with each other. This will mean 
that any party wishing to develop special equipment must have the 
knowledge needed to ensure that the special equipment is  able to 
communicate with all of the booking centre’s technical equipment.  
Option  1 limits the possibilities for technology development and would 
mean that rules quickly become obsolete. By establishing an exact 
requirement on how communication should occu r, we may hinder the use of 
new communication methods that have the potential to be more effective 
and more secure than those prescribed in our regulations. This option may 
also limit the number of actors who are interested in developing the 
necessary tech nical solutions as we would be limiting the number of 
possible solutions that can be used.  
Option  2 – The Swedish Transport Agency's proposal  
Under this option, we will not introduce any new regulation for how 
communication will occur between the special e quipment and technical 
equipment, other than requiring that it be done in a secure manner. This 
means that it will be left to the manufacturers of the special equipment and 
the booking centre’s technical equipment to determine what is a secure 
manner. This  determination will be verified during the certification process. 
This option also leaves it to the manufacturers to decide how they would 
like communication to occur. The manufacturers can either reach an 
agreement on a common standard that they all will use, or each individual 
manufacturer will choose whether they wish to cooperate with another actor 
or possibly even manufacture both types of equipment themselves in order 
to ensure compatibility between the equipment types.  
This option presents a high ris k that the special equipment and booking 
centre’s technical equipment, if manufactured by different manufacturers, 
may not be compatible. This can lead to a situation where the licence holder 
is unable to connect with more than one booking centre, since th e special 
equipment the licence holder has purchased is only compatible with the 
technical equipment at one booking centre or that the licence holder would 
need to acquire more than one type of special equipment. It is possible that   
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manufacturers of techni cal equipment may also manufacture their own 
special equipment and then may choose a communication mode that 
excludes other brands of special equipment. This can create conditions 
where the market for special equipment is dominated by the actors that have 
the capacity to manufacture both the technical equipment and the special 
equipment.  
Despite the fact that it is preferable for all special equipment and technical 
equipment to be compatible, we favour Option  2. The primary motivation 
for this is that we do  not want to limit which technical solutions will be 
permitted. We are of the opinion that it is important for regulations to be 
technology -neutral and function -based so that we avoid getting locked into a 
particular technical solution.  
Manufacturer declaration or certification of special equipment for taxis  
The quality and security of the special equipment is important to ensure the 
portion of the tax inspection that relates to the taxi’s use.  
Option  1 
Under this option, it is the manufacture who eva luates whether the 
prescribed requirements are fulfilled. This is a simpler, less costly option for 
manufacturers. However, this can create a situation where different 
manufacturers interpret the requirements in different ways and that the 
security and qua lity differ depending on the product’s manufacturer.  
Option  2 – The Swedish Transport Agency's proposal  
This option ensures that the security and quality level of the special 
equipment's functions and the information it contains is ensured by an 
independen t party. However, the establishment of a certification 
requirement may create conditions where a smaller number of actors are 
interested in developing special equipment due to the costs associated with 
certification.  
In light of the fact that requirements for security and quality must be set 
equally for the special equipment as they are for the taximeter equipment, 
we propose the adoption of Option  2 in spite of the fact that there is a risk 
that certification costs may decrease interest in manufacturing th e 
equipment.  
Inspection of special equipment for taxis  
Since there are high standards requiring the information collected by the 
special equipment is reliable and cannot be manipulated, the equipment’s 
functions must also be reliable.    
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Option  1 
Under this option, no inspection is done to ensure that the special equipment 
is correctly mounted and installed in the vehicle. Nor will there be regular 
inspections performed to ensure that the equipment is functioning properly 
and that it has not been manipulated.  The police will be the only entity that 
inspects the equipment, and their inspection consists of spot checks, which 
means that there may be taxis in traffic with special equipment that is never 
or seldom checked. This option makes it possible for less est ablished actors 
to use faulty equipment or manipulated equipment within the new category 
for taxi traffic without the risk that their actions will be discovered or that 
their actions will at least be discovered later on in connection with the 
Swedish Tax A gency's inspections.  
Option  2 – The Swedish Transport Agency's proposal  
Under this option, the special equipment will be inspected regularly to 
verify that it is certified, correctly mounted, installed and sealed in the 
vehicle, and that it is functioning properly.  
Since there are high standards requiring that the information collected by the 
special equipment is reliable and cannot be manipulated, the equipment’s 
functions must also be reliable. In order to ensure that the special equipment 
used has reliab le functionality, we believe that the equipment need be 
inspected after installation and on subsequent occasions. Inspection shall be 
done no later than one year from the date of installation or from the most 
recent inspection.  
Option  2 establishes require ments that most closely resembles those for 
taximeter equipment as well as the time interval requirements, and therefore 
offers the best possibility that authorities’ opportunity to perform 
inspections of the new category of taxis will be equal to that for  taxis with 
taximeter equipment. In light of the above, we suggest Option  2. 
7. Which powers are the authority’s discretion based on?  
The Government Offices issued a decision on 5  November  201812 on 
changes to the Government Regulation on taxis (2012:238) and the 
Government Regulation on taxi reporting centres and booking centres for 
taxi traffic  (2016:623) in accordance with Directive (EU)  2015/1535 on a 
procedure for the provision of information in the field of technical 
regulations and of rules on Informatio n Society services. The Ordinance is 
not yet adopted.  
                                                
12 See the Ministry of Enterprise and Innovation’s registration number N2018/05340/RS.    
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11 June  2019  TSF 2018 -134 
  
  
 
 
 
Chapter  8, §§  2 a and 3 in the proposal to amend the Government 
Regulation on taxis gives the Swedish Transport Agency the authority to 
issue regulations, including regulations on special equipment for taxis, the 
use and inspection of such equipment, the inspection body's reporting of the 
results of such inspections of the equipment and detailed content in the 
proof of price.  
§§ 18–21 in the proposal on changes to the Ordinance on reporting centres 
and b ooking centres for taxi traffic authorise the Swedish Transport Agency 
to issue regulations including the requirements that will be set for the 
licence application to operate a booking centre, requirements for the 
technical equipment and a specification of  what information will be 
collected, stored and provided by the booking centre.  
8. Do the regulations comply with or exceed the 
obligations imposed by EU legislative regulations or 
other international rules?  
Provisions within this sector are national ones. Th e regulation therefore 
relates to a sector where there is no EU legal regulation or other 
international regulation.  
The regulations on technical equipment and the regulations on special 
equipment for taxis shall be reported to the European Commission in 
accordance with Directive (EU)  2015/1535 on a procedure for the provision 
of information in the field of technical regulations and of rules on 
Information Society services. The regulations on booking centres for taxis 
shall then be reported in accordance wit h Directive  2006/123/EC on 
services in the internal market.  
9. Do particular considerations need to be taken regarding 
the entry into force date and is there a need for special 
information initiatives?  
The Act on reporting centres and booking centres for taxi  traffic, including 
requirements regarding licences for booking centres, will enter into force on 
1 September  2020. The same date of entry into force shall apply to the 
proposed regulations on booking centres for taxi traffic, regulations on 
technical equi pment at booking centres for taxi traffic and changes to the 
regulations on reporting centres for taxi traffic and regulations on technical 
equipment at reporting centres for taxi traffic.  
The Act  (2018:1125) amending the Taxi Traffic Act  (2012:211), which  
includes requirements for connecting to a booking centre and requirements 
for a fixed price and proof of price, will enter into force on 1  January  2021. 
The proposed regulations on special equipment for taxis, and the changes to 
the regulations on taxi tr affic and the regulations on reporting information   
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11 June  2019  TSF 2018 -134 
  
  
 
 
 
on inspection of taxi -metering equipment and special equipment for taxis 
will enter into force on the same date.  
In order to allow the manufacturers time to develop technical equipment and 
special equipmen t, and to provide Swedac with time to accredit certification 
bodies who can then certify the equipment, a decision on these regulations 
should be reached as soon as possible. Given that the notification shall be 
made in accordance with Directive  2006/123/E C and Directive 
(EU)  2015/1535, we believe that the regulations can be decided by 
December  2019 at the earliest.  
Information collection efforts have already begun; see more about this in 
Section  E. 
B. Transport policy goal completion  
The overall objective  of Swedish transport policy is to ensure a socially efficient 
and long -term sustainable transport supply for citizens and businesses 
throughout the country. Under the overall objective, there are performance 
objectives and health, environment and safety ( HES) objectives with a number 
of prioritised areas.  
The performance objective  is to create accessibility for people and goods. The 
design, functioning and use of the transport system shall help provide everyone 
with basic accessibility, with good quality a nd usability, as well as contribute to 
the national development dynamic. At the same time, the transport system must 
be one of equality, i.e. equally meet the transport needs of both men and 
women.  
The HES objective  concerns health, environment and safety.  The design, 
functioning and use of the transport system shall be adapted so that no one is 
killed or seriously injured. It shall also help achieve the overall generational 
objective for the environment and the environmental quality objectives, as well 
as contribute to improved health.  
10. How do the regulations affect the performance 
objective?  
In the opinion of the Swedish Transport Agency, the proposed regulations 
will not affect the policy objectives in any substantial way, nor will they act 
counter to the objective.  
11. How do the regulations affect the HES objective?  
The proposal itself is not expected to have a significant effect on safety, 
environment and health, since the changes are not intended to change how 
taxi traffic is carried out in practice, only h ow the information relating to it 
shall be handled.    
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C. Companies  
12. How many companies are affected, in which sectors do 
they operate and how large are these companies?  
Several industries are affected by the regulation. The provisions adopted in 
the legislation primarily affect the taxi licence holders who are currently 
granted exemptions from the requirement for taximeter equipment. These 
licence holders are also affected by the proposed regulations, primarily due 
to the requirements for certification and inspec tion of the special equipment, 
but also to a certain extent by the requirements that are established for 
licensable booking centres.  
Other companies involved include those that are interested in operating a 
licensable booking centre, for example, those com panies that already handle 
orders for taxi companies. Technology companies that would like to 
manufacture technical equipment and/or special equipment for taxis and 
inspection bodies are also affected.  
Taxi traffic licence holders  
There are currently a tot al of 8  518 licence holders for taxi traffic and 
18 113 vehicles13 registered for taxi traffic. There are 347 licence holders14 
who collectively have 1  999 vehicles15 that have been granted exemptions 
from the requirement for taxi -metering equipment. Of the l icence holders 
who have vehicles registered for taxi traffic who are not equipped with taxi -
metering equipment, approximately  
 50 % of firms have one vehicle,  
 14 % of firms have two vehicles,  
 27 % of firms have from three to 10 vehicles,  
 9 % of firms have 11 or more vehicles.16 
Licensable booking centres  
The new category for taxi traffic entails the introduction of a new type of 
taxi operation. There are currently no licensable booking centres on the 
market today. Both natural and legal persons will be given the opportunity 
to apply for a licen ce to operate a booking centre. It is difficult to assess 
how many entities will choose to apply for licences, since it is only after 
                                                
13 Swedish Transport Agency, Road Traffic Register as of 4  February  2019.  
14 Swedish Transport Agency, Road Traffic Register as of 11  September  2018.  
15 Swedish Transport Agency, Road Traffic Register as of 10  September  2018.  
16 Swedish Transport Agency, Road Traffic Register as of 11  September  2018.    
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11 June  2019  TSF 2018 -134 
  
  
 
 
 
notification of these proposed regulations that it becomes known to the 
market which d etailed requirements will be placed on licensable order 
centres. It is only after this time that entities will decide whether they wish 
to apply for such a licence.  
Possible interested entities include organisations that already conduct 
operations as a boo king centre in its current form, especially those that 
handle publicly funded transport. There are currently approximately 350 
booking centres in Sweden.17 
Other interested parties may include entities that run reporting centres – 
there are currently six ap proved reporting centres. It is also possible that 
there will be other interested companies who have developed similar 
equipment and have an interest in the taxi industry, but we are unable to 
estimate how many companies fit this description.  
Manufacturers  of technical equipment  
Much the same as with licensable booking centres, it is difficult to assess 
how many parties will be interested in manufacturing technical equipment 
for the booking centres. Possible interested parties are the five who 
manufacture t echnical equipment for the reporting centres, but also those 
who develop systems for the existing booking centres or similar operations. 
We have no knowledge of how many there are.  
Manufacturer of special equipment for taxis  
It is uncertain which companies  will manufacture special equipment for 
taxis, as this is entirely new equipment. There are a handful of taximeter 
manufacturers on the Swedish market who may also be interested in 
manufacturing special equipment, and there are also international companies  
that manufacture similar equipment. Other companies that may be interested 
are companies that manufacture electronic driving logs with associated 
equipment that processes vehicle data for traffic planning and follow -up. 
We have no information regarding ho w many such companies there are.  
Approved inspection bodies  
There are just over 50 inspection bodies that are accredited to inspect 
taximeter equipment.18 We believe that a number of these bodies will also 
choose to be accredited to inspect the special equi pment in order to ensure 
that they can accommodate all taxi vehicles. However, the level of interest 
                                                
17 Prop. 2017/18:239, p.  97. 
18 Swedacs website, 20  February  2019, 
http://search.swedac.se/sv/ackrediteringar?mode3_accarea_l1=Taxameter&mode3_accarea
_l2=&mode3_accstd=&mode3_docs=    
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for inspection bodies will depend upon how large the market is for special 
equipment, which will in turn affect the demand for the inspection of such 
equip ment.  
There may also be new companies that would like to be accredited for 
inspection.  
13. How much time will companies have to spend as a result 
of the regulation, and what impact will it have on their 
administrative costs?  
Taxi traffic licence holders  
We do not believe that the regulation will entail new administrative costs for 
the companies that hold taxi traffic licences. There are already regulations in 
place under the ordinance stipulating that all taxi traffic licence holders shall 
register their taxi v ehicles with the Swedish Transport Agency, regardless of 
whether the vehicles are equipped with a taximeter or are granted 
exemptions from the requirement for taximeter equipment. With the 
introduction of the new category, the licence holders who choose to  be 
included shall report which booking centre their vehicles will be connected 
to, but this is also stipulated under the ordinance and is not a consequence of 
the proposed regulations.  
Therefore, the licence holders will incur administrative costs, but th e costs 
are not a consequence of the regulations. However, other costs, such as costs 
of purchasing special equipment, will be affected by the proposed 
regulations (this is described further in Section  14). 
Licensable booking centres  
Pursuant to the provisions in the new legislation, those who wish to operate 
a booking centre in the new category will need to apply for a licence from 
the Swedish Transport Agency.19 Such an application needs to be made on a 
single occasion. The proposed regulations stipu late that the application must 
include documentation that shows how the applicant meets the requirements 
for information security.  
                                                
19 The Swedish Transport Agency will collect an application fee from those wishing to 
apply to operate booking centres as well as an annual supervision fee for anyone who is 
licenced to operate a booking centre. These fees have not yet been determined definiti vely, 
but it can be useful to make a comparison with taxi traffic reporting centres where the 
application fee is SEK  7 500 and the annual supervision fee is SEK  5 000 (TSFS 
2016:105).    
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In a previous inquiry20 done in connection with the introduction of the 
reporting centres, we calculated how much time would l ikely be spent on 
reporting to demonstrate that the requirements for information security are 
fulfilled. The inquiry was completed in 2016, and the information was 
reconciled with the parties who expressed an interest in operating a 
reporting centre. We ha ve been unable to perform a corresponding 
reconciliation in this inquiry as we do not know which entities or how many 
applicants will apply to become a licensable booking centre. Despite this, 
we believe that the information from the inquiry on reporting c entres can at 
least offer a general idea of the amount of time that will be spent and what 
the cost per company may be, and we can therefore make estimates based 
on this inquiry as well.  
The time spent to complete the documentation on the information security 
management system which must be attached to a licence application is 
estimated to be 4  800 minutes or 10 working days per company.21 This only 
needs to be done on a single occasion and  revisions only need to be made if 
the system changes. At a wage of SEK  316 per hour for a manager in 
purchasing, logistics and transport, the cost amounts to an estimated 
SEK  25 300 per company.22 Since we are uncertain how many companies 
are interested, w e cannot specify a total of estimated costs.  
In addition, the booking centre’s operations manager shall establish 
documentation demonstrating how the requirements for the operating 
environment are met. The estimate that was made in connection with the 
introduction of the reporting centres found that it would take approximately 
half as long as the time spent to establish documentation for management 
systems, i.e. 2  400 minutes or five working days. If this calculation is also 
used to estimate the time spent by the booking centre, the requirement 
equates to a cost of approximately SEK  12 650 per company. We are unable 
to determine a total estimated cost here as well.  
Booking centres will need to establish systems, routines and manuals for 
processing the inform ation that will be collected, stored and provided. This 
applies to both technical routines and routines for information security. The 
                                                
20 The Swedish Transport Agency’s proposal impact assessment on reporting  centres for 
taxi traffic and their technical equipment, and clarification of price information decal, 
18 January  2016, TSF  2015 -37. 
21 See Annex  2, TSF 2015 -37. 
22 The cost is calculated based on an average monthly salary for a purchasing, logistics and 
transport manager of SEK  50 600, as reported by Statistics Sweden. We assume that 
average working hours per month per person is 160  hours, which equates to a salary cost of 
SEK  316/hour and SEK  5.27/minute. https://www.scb.se/hitta -statistik/statistik -efter-
amne/arbetsmarknad/loner -och-arbetskostnader/lonestrukturstatistik -privat -sektor -
slp/pong/tabell -och-diagram/tjansteman -2016/genomsnittlig -manadslon -efter-yrke/    
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majority of this work only needs to be done once and then updated on a 
regular basis when changes are made. It is difficul t to estimate costs here, 
especially since we believe that costs will vary from company to company 
depending on which systems already exist in the respective operations. If an 
existing, non -licensable booking centre chooses to apply to be a licensable 
book ing centre, It will likely already have a variety of routines and systems 
in place, while conditions will likely be different for a completely new 
entity.  
Manufacturers of technical equipment  
Companies who would like to manufacture the technical equipment that will 
be used by licensable booking centres shall conduct their operations in 
accordance with a documented information security management system. 
These companies shall also document which routines and methods they use 
in their manufacturing. How exten sive the costs are in establishing and 
updating this documentation can depend on which system the manufacturer 
chooses and whether the business already has established systems and 
routines in place.  
In connection with the introduction of reporting centres,  the estimated time 
required for documentation of all these measures amounted to 10  560 
minutes or 22  working days. The calculation was made in consultation with 
the taximeter manufacturers who expressed an interest in developing the 
technical equipment. I f a corresponding amount of time applies for those 
who will manufacture the booking centre’s technical equipment, this would 
equate to a cost per company of SEK  55 650.23 Since we are uncertain how 
many companies are interested, we cannot specify a total of  estimated costs.  
Any party who chooses to manufacture technical equipment shall also 
ensure that the equipment goes through the certification process. The 
requirement for certification is stipulated in the Ordinance on reporting 
centres and booking centre s for taxi traffic, therefore, this is an 
administrative cost that is not dependent on the proposed regulations. 
However, the extent of the requirements we establish in the proposed 
regulations can affect how extensive the certification process will be, an d 
thus the cost of certification.  
Manufacturer of special equipment for taxis  
Any party choosing to manufacture special equipment shall ensure that the 
equipment goes through the certification process, as stipulated in the 
                                                
23 The cost is calculated based an average monthly salary for the purchasing, logistics and 
transport manager of SEK  50 600, as reported by Statistics Sweden. This equates to a salary 
cost of SEK  316/hr and SEK  5.27/minute.    
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requirements in the regulations. It is very difficult to determine what the 
costs will be for certification since there is no comparable equipment that 
has already gone through a certification process.  
The cost of certification will have an impact on the price of the special 
equipment. Th e fact that, at least initially, the equipment mainly applies to a 
market comprising approximately 2  000 vehicles will also affect the price.  
Pursuant to the proposed regulations, the special equipment shall fulfil the 
Electromagnetic Compatibility (EMC) r equirements in accordance 
with ECE Regulation  10.24 This means the equipment will need to be type -
approved. Type -approval is issued by the Swedish Transport Agency. The 
agency’s assessment of whether the equipment meets the requirements 
under the regulation s requires that a ‘technical service’ performs testing of 
the product. A technical service is an organisation or body that is approved 
as a testing laboratory and that has registered with the EU and ECE25 
respectively to perform tests in connection with typ e-approvals. The time 
needed for the type -approval process itself will vary depending on the 
manufacturer’s level of preparation. For type -approval, including the initial 
inspection and follow -up inspections, the Swedish Transport Agency will 
collect a fee  at an hourly rate of SEK  1 400. There are also additional costs 
for testing that is performed by the technical service. We have been in 
contact with a technical service that estimates the cost for testing the special 
equipment to be SEK  50 000. 
Additional ly, those who manufacture special equipment shall conduct their 
operations in accordance with a documented information security 
management system and shall document the routines and methods they use 
during manufacturing. How extensive the costs are in esta blishing and 
updating this documentation can depend on which system the manufacturer 
chooses and whether the business already has established systems and 
routines in place. As with the manufacturers of the booking centres' 
technical equipment, a comparison  can be made with the inquiry that was 
conducted for the introduction of reporting centres. Therefore, the estimated 
cost is the same for these manufacturers, i.e. SEK  55 650 per company. 
Since we are uncertain how many companies are interested, we cannot 
specify a total of estimated costs.  
                                                
24 The ECE regulations are annexes to the 1958  Agreement to Adopt Harmonised Technical 
Prescriptions for Wheeled Vehicles or for equipment and parts that c an be fitted or used on 
such vehicles.  
25 The ECE is the UN’s European commission.    
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Approved inspection bodies  
Inspection bodies who would like to become certified to inspect the special 
equipment for taxis will need to establish new manuals for these 
inspections. Since manufacturers will need to train inspection bodies and 
provide them with information on how the equipment should be inspected, 
we believe the time required by inspection bodies will be relatively small.  
There may also be companies who will apply for accreditation for the first 
time in ord er to be permitted to perform inspections of the special 
equipment. Costs associated with accreditation will be incurred both by the 
bodies that are already accredited, to expand their level of accreditation, and 
by the new companies wishing to apply for a ccreditation. In 2020, fees for 
accreditation are expected to be approximately SEK  30 000 for the 
inspection bodies that would like to be accredited for both taximeters and 
special equipment. If an inspection body only wishes to be accredited for the 
inspe ction of special equipment, the fee is expected to be approximately 
SEK  20 000. 
14. What other costs will companies incur as a result of the 
regulations and what operational changes might they 
need to make?  
Taxi traffic licence holders  
As stipulated in the provisions of the new legislation, licence holders will 
incur costs associated with the purchase of special equipment and for 
connection to one or more licensable booking centres. The extent of these 
costs, especially as they pertain to the cost of purchas ing the special 
equipment, will be affected by the proposed regulations’ requirements for 
certification of the special equipment.  
Proposition  2017/18:239 showed that the purchase price for the special 
equipment would likely be approximately SEK  1 000.26 At the time of the 
calculation, it was not clear if there would need to be certification 
requirements for the special equipment, meaning that the calculation does 
not include certification costs.  
The certification requirement for special equipment would mainl y affect 
vehicles that are currently exempt from the requirement for taximeter 
equipment. Even if all 2  000 of these vehicles were to be equipped with 
special equipment, a purchase cost of SEK  1 000 per unit would mean that 
the manufacturers' collective re venue from sales would amount to 
SEK  2 million. Of course, if more than one manufacturer produces the 
                                                
26 Prop. 2017/18:239, p.  93.   
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special equipment, this amount will be divided across several companies. 
The amount must cover manufacturing and development costs.  
Although it is difficu lt for us to estimate the costs for manufacturing and 
development of the special equipment since it is a brand new product, we 
believe that revenues of SEK  2 million are on the low end of likely 
estimates, and therefore a purchase cost of SEK  1 000 is also  on the low end 
of what is likely. Since the proposed regulations will also establish 
requirements for certification and EMC compatibility, manufacturers will 
incur additional costs, which will in turn affect the purchase price of special 
equipment that ha s been certified and type -approved.  
Any licence holder who decides to enter into the new taxi category will also 
need to pay for the installation and inspection of the special equipment. 
These are new costs for vehicles that have previously been granted 
exemptions from the requirement of taxi -metering equipment. The costs for 
installing a taximeter have been estimated to be between SEK  4 000 and 
SEK  10 00027, while the inspection and maintenance of a taximeter has been 
estimated to be between SEK  1 500 and S EK 3 100 per year.28 Our 
assessment is that costs associated with the special equipment will be lower 
since this type of equipment will have fewer functions than a taximeter.  
Since 50  per cent of the affected licence holders only have one taxi vehicle, 
their costs for installation and inspection will amount to the cost of one 
vehicle. Other licence holders, who have multiple vehicles, will need to 
multiply the cost by the number of vehicles in order to determine their total 
cost. 
If all of the taxis that are  currently granted exemptions from the taximeter 
requirement were to be equipped with special equipment, the cost for this 
entire group would be approximately at SEK  8 million for installation and 
an annual cost of SEK  3 million for an inspection when usin g an estimate29 
in line with the lower range of costs for the taximeter equipment.30 
The proposed regulations will allow entities other than approved inspection 
bodies to install the special equipment. This may mean that a licence holder 
who handles the inst allation of the equipment himself/herself may be able to 
get a slightly lower cost from the inspection body for the inspection of the 
installed equipment.  
                                                
27 SOU  2016:86  p. 391. 
28 Prop. 2017/18:239, p.  91. 
29 At an installation cost of SEK  4 000 per vehicle for 2  000 vehicles.  
30 At an inspection cost of SEK  1 500 per vehicle for 2  000 vehicles.    
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The licence holders will also incur costs for staff training, in how systems 
shall be managed, how the drivers will identify themselves and how the 
special equipment will function.  
Licensable booking centres  
The booking centres will need to purchase certified technical equipment in 
order to be able to collect, store and provide the prescribed informatio n. The 
cost of technical equipment at a booking centre has been estimated at 
SEK  1 million.31 This does not include the costs of information collection 
and storage.  
The proposed regulations also contain specific requirements on tasks that 
the booking centre ’s technical equipment shall be able to perform. For 
example, the equipment must be able to link together information on the 
vehicle identification number with the vehicle registration number and it 
must have a technical solution that is able to identify d rivers in accordance 
with the requirements of the regulations. These requirements may have an 
impact on development costs for the technical equipment, thus impacting 
the booking centre’s purchasing costs, but while we do not have access to 
information abou t what this may mean in terms of increased costs, we 
believe that the amount indicated, SEK  1 million, is reasonable.  
Due to the proposed regulation, booking centres will need to train their staff 
in relation to the new regulations and how they should be a pplied.  
Manufacturers of technical equipment and special equipment for taxis  
Manufacturers will also need to train relevant staff members in relation to 
the new regulations so that they are aware of what requirements apply to the 
equipment they will manufa cture. The regulations themselves are not 
particularly extensive, however, the extent of training needed depends 
largely on which companies are involved and the background of their staff 
members. Therefore, it is difficult to calculate the extent of traini ng that will 
be needed and how much it will cost.  
The special equipment manufacturers will also need to train inspection 
bodies and provide them with information on how the equipment should be 
inspected.  
                                                
31 Prop. 2017/18:239, p.  93. This information came from the technical assessment that was 
performed in connection with the inquiry SOU  2016:86 Taxi and ride -sharing, today, 
tomorrow and the  day after tomorrow.    
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Approved inspection bodies  
Any inspection body that chooses to apply for accreditation to inspect the 
special equipment will be required to provide further training for its staff. 
Inspection bodies will also need to purchase sealing tools.  
15. To what extent might the regulations affect competitive 
business con ditions?  
Even if the new category for taxi traffic is adopted under the legislation, the 
regulations are voluntary to the extent that no licence holders will be 
compelled to connect to a booking centre or to obtain special equipment for 
their taxi vehicles . Each taxi licence holder will have the opportunity to 
decide whether they would like to join the new category or if they would 
prefer to have a taximeter and connect their vehicles to a booking centre. 
The proposed regulations may have an impact on the l icence holders' choice 
between taximeter equipment and special equipment, primarily because the 
requirements affect the purchase price of the special equipment.  
Depending on how extensive the costs are for entering the new category, the 
proposal may affect  a small portion of the total taxi market, a larger portion 
or have no effect at all. Therefore, in terms of the competitive conditions in 
the sector, the proposed regulations may have a small or large impact or no 
impact at all.  
16. How might the regulations affect companies in other 
ways?  
If it ends up being less costly to equip taxis with special equipment 
compared to taxi -metering equipment, there may be more applications for 
taxi licences. However, we do not believe this will occur in significantly 
large n umbers as the requirements for taxi licences and taxi driver’s licences 
will remain unchanged.  
17. Does the drafting of the regulations need to take small 
companies into particular consideration?  
A company’s size may be significant when it comes to deciding ho w many 
booking centres it is possible to connect to. If the costs for connecting to a 
centre end up being high, it can be difficult for the smallest companies to 
connect to more than one booking centre.  
A company’s size may be significant in terms of being  able to conduct 
operations as a licensable booking centre. In light of the costs of 
manufacturing, developing  and certifying the technical equipment, it is 
likely that it will primarily be larger companies that will be able bear the 
costs associated with such an operation. They will also need to connect as 
many licence holders as possible if they are to achieve profitability. It may   
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also be assumed that larger companies will have access to more resources to 
perform administrative tasks.  
D. Summary of impacts  
Affected party  Impacts that cannot be calculated  Estimated 
impact (SEK 
thousands)  Comments  
 Advantages  Disadvantages  +/–  
Companies  Facilitates the 
manufacture of 
technical and 
special 
equipment by 
specifying which 
requirements 
must be fulfilled.  Requirements 
for certification, 
installation and 
inspection of 
special 
equipment 
impacts the 
purchase price.  
Requirements 
may affect how 
many parties 
have the 
opportunity to 
become 
licensable 
booking centres.    
Citizens  Requirements 
on the evidence 
of price provides 
taxi customers 
in the new 
category with 
clearer 
information 
regarding the 
price of their taxi 
journey.  Prices in the 
new category 
may end up 
being slightly 
higher to 
compensate for 
certification 
costs and other 
costs related to 
the proposed 
regulations.    
The State and 
others  Facilitates tax 
inspections by 
specifying what 
information shall 
be submitted to 
the Swedish Tax 
Agency and by 
establishing 
requirements for 
the reliability of 
the information.  -   
Externalities  -    
Total      
   
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E. Consultation  
The proposed regulations have been developed in consultation with the 
Swedish Tax Agency and Swedac.  
The Swedish Transport Agency has also maintained regular contact with 
industry organisations, taximeter manufacturers, technical companies and  
certification bodies. The Swedish Transport Agency held a workshop on 
6 November  2018, with representatives from several different industries and 
other authorities participating. We have been in contact with many of the 
participants after the workshop. So me have voluntarily shared their 
viewpoints and others have been given the opportunity to give feedback on 
draft regulations.  
If you have any questions regarding this impact assessment or any opinions 
you would like to share, please contact us:  
Jenny Bragg, analyst  
jenny.bragg@transportstyrelsen.se  
010-49 564 38 
Nenne Åman, legal adviser  
nenne.aman@transportstyrelsen.se  
010-49 558 95   
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Annex  
Personal information  
The personal information (direct and indirect) that the Swedish Tax Agency 
needs for its tax inspection primarily consists of information about which 
driver has accepted a driving assignment, the registration number of the 
vehicle, to which licence holder the respective vehicle is registered for taxi 
traffic, the recipient account or other informa tion on payment methods of 
the driving assignment and the recipient account bank or another receiving 
system where remuneration is received. It may be the case that a driver or 
the licence holder has protected personal information. This means that 
informat ion from the booking centre ends up being in a higher protection 
class than it otherwise would be.  
In addition, the Swedish Tax Agency needs information on payment, the 
time of payment (amount excluding VAT and including VAT), payment 
method and the route mileage for a particular driving assignment. This 
information shall be stored in  the booking centre’s technical equipment.  
However, the Swedish Tax Agency does not need information regarding 
who ordered or took the journey or information on the account num ber for 
payment for the journey. Therefore, names, account numbers and other 
information that can be directly or indirectly linked to a purchaser or rider 
shall not be collected and stored in the technical equipment.  
The Swedish Tax Agency needs informatio n about driving assignments 
completed under the scope of the exemption in Chapter  2 b, § 5 of the Taxi 
Traffic Act (publicly funded transport). This can include transportation 
services, for example. However, any connection to who took the trip shall 
not be  collected and stored in  the booking centre’s technical equipment.  
In relation to some technical vehicle information in the Road Traffic 
Register or to registered body codes, this information in and of itself could 
be adequate to conclude that a vehicle ma y have been used for passenger 
transport for an individual with disabilities. However, information about the 
purchaser, rider or other information that can be directly or indirectly 
connected to these individuals shall not be registered or stored in the 
technical equipment or in the special equipment for taxis. Therefore, it will 
not be possible to link together information on a certain vehicle and its 
characteristics with information about the rider, thus registering sensitive 
personal information, such as  information relating to disabilities.  
As for the collection and storage of information on route mileage, an  overly 
detailed review of how a taxi has travelled may be contrary to the basic 
principles of data minimisation. Article  5.1 c in the General Data Protection   
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Regulation (GDPR) stipulates that personal data shall be adequate, relevant 
and not overly extensive in relation to the intended purposes for which the 
data are processed. As long as a data controller has a legitimate, specific and 
explicitly st ated purpose for processing the data, processing is permitted. 
But beyond this, a new restriction applies. It does not restrict what personal 
data may be processed, only the data that is needed to fulfil the purpose. For 
its tax inspections, the Swedish Ta x Agency does not need to collect 
detailed information about how a taxi has travelled (positioning). By 
collecting information about the odometer status or the cumulative route 
mileage the vehicle has travelled from or via the vehicle, rather than through 
GPS positioning, the risk that information is collected that reveals how a 
taxi has moved during a driving assignment is minimised.  
In summary, it will therefore be unnecessary to store any information in the 
booking centres’ technical equipment or in the special equipment for taxis 
which directly or indirectly relates to the registration of the riders or how 
they have travelled.  
However, the booking centres will inevitably process certain information 
about travellers and their journeys under the scope of t heir booking 
activities. Since this occurs under the same activities as the collection of 
information needed for the Swedish Tax Agency’s inspections, there is a 
risk that the information will be comingled and that it will then be possible 
to identify indi vidual travellers in the information collected for the tax 
inspections. Therefore, it is necessary to take measures to ensure comingling 
does not occur and that it is not possible to transfer any information that 
directly or indirectly relates to a purchas er or the traveller from the booking 
centre’s operations to the technical equipment at a booking centre that 
collects information for the Swedish Tax Agency’s inspections. Therefore, 
the proposed regulations contain a requirement that information shall be 
kept separate and that strict access protections are used, i.e. that strict 
requirements are set for confidentiality.  
 
What are the personal privacy risks for registered data subjects?  
There are risks for passengers’ privacy since their personal informatio n will 
need to be processed by the booking centre in order to plan journeys and 
process orders and payments. Therefore, there is a risk that the booking 
centre will record information about passengers (who they are, where they 
travelled) in their technical  equipment despite the fact that this passenger 
information should not be processed.  
The Swedish Tax Agency does not need information on passengers and will 
not request any such information. The risk that the agency will nonetheless 
receive passenger information, which is stored in the technical equipment   
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despite stipulations in the regula tions that prohibit this, should be small 
since the booking centre shall submit the information electronically, 
according to an established format and specific elements.  
Another risk is that the booking centre may disclose passenger information 
to a third party. §  28 in the Act  (2014:1020) on reporting centres and 
booking centres for taxi traffic (LRCBC) states that the booking centre and 
any individual who is a member or has been a member of the staff at any 
such centre may not make unauthorised disclosure s of taximeters if it can be 
assumed that there is a risk that the person who submitted the information 
may be exposed to damage or if the information is disclosed.  
We strive to limit the above risks by requiring that booking centres conduct 
their operatio ns in accordance with a documented management system for 
information security.  
Additionally, the manufacturers of the booking centres’ technical equipment 
and the manufacturers of the special equipment for taxis shall conduct their 
operations in accordance  with a documented management system for 
information security. This, in turn, gives rise to the need for requirements 
regarding the completion of secure routines for data processing.  
We have stipulated that the prescribed shall be kept separate from other 
information that is needed for the booking centre’s operation. If, 
nonetheless, there is comingling of information on drivers that we prescribe 
with the booking centre's other information concerning drivers, the 
confidentiality provisions shall apply.  
What  impact will the proposal to collect, store and provide information 
for privacy protection have on other obligations to store information?  
These are two different systems. The provisions of the Swedish Accounting 
Act shall be followed even if additional pr ovisions apply under our 
proposed regulations.  
What will the impact of the proposed search restrictions on privacy 
protection be?  
We believe there should be a high level of privacy protection. When the 
Swedish Tax Agency requests information from the booking centre, they 
will be given a driver code for the taxi driver. In order to convert the driver 
code to a personal identification number, the Swedish Tax Agency will 
contact the Swedish Transport Agency, which can assist with this 
information.    
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What in formation do data subjects receive concerning the collection of 
personal information?  
The booking centre is responsible for informing data subjects about the 
collection of personal information.  
The booking centre is the entity that actually has control ove r the processing 
of the personal information that takes place within the licensable operation, 
and the centre is therefore considered the data controller. It is the data 
controller that bears the bulk of the responsibility under the General Data 
Protection  Regulation (GDPR). Once the Swedish Tax Agency, in turn, 
receives the information for its tax inspections, the agency becomes a data 
controller in terms of the processing they perform within the framework of 
their activities.  
Who are other potential recip ients? The police, individuals requesting 
registry extracts, licence holders for taxi operations?  
Pursuant to §  25 in the Act on reporting centres and booking centres for taxi 
traffic (LRCBC), upon request by the taxi licence holder, the booking centre 
shall disclose information collected and stored regarding the licence 
holder’s activities. The information shall be given to the licence holder. The 
reason for this provision is that a licence holder may need access to the 
information in order to fulfil its a ccounting and declaration obligations, for 
example, if accounting has been done during a fire or other incident. There 
is no new information that must be transferred between the booking centre 
and licence holder for such a situation.  
In addition, there are  no new recipients beyond the Swedish Tax Agency.  
§ 28 in the Act on reporting centres and booking centres for taxi traffic 
(LRCBC) states that the booking centre and any individual who is a member 
or has been a member of the staff at any such centre may n ot make 
unauthorised disclosures of information the centre collects and stores if it 
can be assumed that there is a risk that the person who submitted the 
information may be exposed to damage or if the information is disclosed.  