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MOLO relies on early oversight: Rhineland-Palatinate must learn from the experiences with Uber.
With a nationwide initiative, the association addresses the licensing authorities and calls for the full use of existing legal options before taxi-like platform transports become permanently established.
The association has handed a guidance document to all districts and independent cities of the country. It is intended to help traffic authorities scrutinize applications for rental-car permits more closely. The background is the concern that platform-mediated rental-car traffic are increasingly taking on functions traditionally reserved for the taxi trade—but without being subjected to the same regulatory requirements.
Competition under unequal conditions
As MOLO emphasizes, the problem lies in different rules of the game. Taxi companies operate with government-set tariffs, are subject to a transport obligation, and require licenses. Rent-a-car companies, on the other hand, may set their prices freely and must, after each trip, in principle return to the operating base, unless there is a new assignment.
Precisely this return obligation is frequently circumvented in practice, argues the association. Platform-mediated vehicles are thereby in many places almost permanently on the city streets and could effectively operate like taxis. The consequence would be competitive disadvantages for regulated operators, who must also comply with tariff and labor-law requirements.
„Where mobility becomes a pure price issue, fair working conditions, reliable quality and, in the end, the mobility provision in the regions are put under pressure,“ says MOLO managing director Guido Borning.
A view beyond the taxi trade
The association does not limit its criticism to the effects on taxi and rental-car companies. MOLO points to the particular structure of a geographically large state like Rhineland-Palatinate, where different modes of transport are closely interwoven. Line buses, taxis and rental cars each have their own roles within the mobility chain.
According to the association, a concentration of platform providers on particularly profitable trips could, in the long term, also weaken existing transport offerings. If economically attractive trips were siphoned off, this could impair the financing and stability of other mobility offerings.
“We must not view the individual modes of transport in isolation,” explains Managing Director Heiko Nagel. “New mobility offerings could be a sensible addition, but must not be based on circumventing existing rules.”
Hamburg as a Role Model
As an example, MOLO cites the Hanseatic City of Hamburg. There, a large platform market has not yet developed in a comparable way to Berlin or Cologne. The association attributes this to a consistent permitting practice.
The core of the so-called Hamburg Model is an intensive examination of rental-car applications already before the grant of the permit. According to MOLO, this is carried out on the basis of the existing Passenger Transport Act and without additional statutory regulations.
This view is supported by current court rulings. The Federal Court of Justice confirmed in early June 2026 the validity of the return-to-base requirement for platform-mediated rental cars. In addition, the Hamburg Administrative Court ruled that authorities may attach specific conditions to rental-car permits in order to prevent circumvention of the return-to-base requirement via platform apps.
Brochure for the Authorities
The handout now presented is intended to transfer these experiences to Rhineland-Palatinate. It describes six central areas of review in rental-car applications, explains possible steps in the review, and includes a checklist for administrative practice.
MOLO explicitly advocates a preventive approach. If a platform provider is already on the market with a larger fleet, later corrections are often associated with lengthy administrative and court proceedings.
In parallel, the association supports municipalities that want to introduce minimum transport tariffs under Section 51a of the Passenger Transport Act. Cities such as Heidelberg and Leipzig have already made use of this option. From MOLO's perspective, the two instruments complement each other: minimum prices can limit distortions of competition; however, effective protection begins already with the approval of new mobility services.
With its initiative, the association is setting an early course. Whether Rhineland-Palatinate authorities follow Hamburg's example is likely to determine how the market for platform-mediated mobility offerings in the state develops in the coming years.
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