§19-506(d): Driving for Hire Without a TLC License

In short: §19-506(d) is the driver half of unlicensed activity. It covers anyone who drives a TLC-licensed vehicle for hire without both a valid TLC driver's license and a valid New York State class A, B, C or E license. At OATH the civil penalty is $1,500 for a first violation and $2,000 for a second within 36 months. If your TLC license lapsed or was suspended, stop driving for hire until it is restored.

What the law says

Admin Code §19-506(d): "Any person, other than a person holding a driver's license issued pursuant to section 19-505 and a New York state class A, B, C or E license, neither of which is revoked or suspended, who drives or operates for hire a licensed vehicle in the city except a commuter van, shall be guilty of a violation."

In plain English, you need two licenses at the same time, and neither may be suspended or revoked:

1. A TLC driver's license. §19-505 says TLC now issues a "universal" license that covers both taxis and FHVs.
2. A New York chauffeur-class license (class A, B, C or E). §19-505(b) requires TLC applicants to hold a New York State chauffeur's license.

The vehicle here is already licensed; the problem is the driver. If the vehicle has no TLC license, see §19-506(b)(1).

Who gets this summons

• A driver whose TLC license has expired, been suspended (for example for unpaid fines or a missed drug test), or been revoked, and who keeps driving.
• A person without any TLC license driving someone else's TLC-plated car.
• A driver whose New York license was suspended or downgraded, even if the TLC license looks active.

Commuter van drivers are excluded from §19-506(d); commuter van violations have their own penalty scale in §19-506(i).

19-506(d) or TLC rule 80-11?

TLC also has its own rule. Rule 80-11(a) says a driver "must not operate a Taxicab, a For-Hire Vehicle and/or a Street Hail Livery ... while his or her TLC Driver License is revoked, suspended or expired." The penalties are very different, so the code on your summons matters.

How often it appears

Summonses citing §19-506(d) have fallen from 2,751 in 2014 to under 200 a year since 2023. Over the same period, OATH's catalog shows 80-11(a)(1) rising to 1,420 in 2025. The data can't say whether one replaced the other, but it is consistent with TLC charging more of these cases under its own rule.

Penalties

Two notes. First, the seizure law (§19-506(h)) lists subdivisions (b), (c) and (k), not (d), so §19-506(d) alone is not a seizure trigger under that section. Second, the vehicle's owner can face separate charges for allowing an unlicensed driver; for street hail liveries, for example, TLC rule 82-12(e) sets $1,500 for a first offense.

When the problem is your DMV license

Many drivers focus on the TLC license and forget the state one. TLC rule 80-11(c) says a driver must not operate a taxi, FHV or SHL "without a Valid Chauffeur's License," or while their "driving privileges in New York State have been suspended or revoked." A driver caught doing so has their TLC license summarily suspended, and the fine is $350 and suspension until compliance for a first violation, $500 for a second within 36 months, and revocation for a third. Rule 80-11(c)(4) also says you must "immediately surrender" your TLC license if your state chauffeur's license or driving privileges are revoked.

So if DMV suspends your license (for example for unpaid tickets or insurance lapses), your TLC license is effectively unusable until DMV restores it. Fix the DMV side first, then confirm TLC shows your license as active.

What to do now

• Check your license status in TLC UP and your DMV license status. Get documents showing the status on the date of the summons.
• If your TLC license is suspended, find out why and what lifts it; see what to do if your TLC license is suspended.
• If it expired, start the renewal. Don't drive for hire until it is renewed; TLC rule 80-11(b) calls driving after expiry and before renewal unlicensed activity.
• Answer by the hearing date. OATH hearings are usually by phone or written defense online, if eligible.

Points to discuss with your lawyer

General information only:

• License status on that date. A renewal or reinstatement that was already in effect may defeat the charge.
• "For hire." TLC must show you were driving the licensed vehicle for hire, not just moving it.
• Duplicate charges. If you also got an 80-11 summons for the same act, ask about Admin Code §19-507.1(e), which limits duplicate penalties for taxi and FHV drivers when violations are substantively the same.