§19-528(a): Running a TLC-Licensed Business Unlicensed

In short: §19-528(a) is aimed at businesses, not drivers. It says nobody who is required to hold a TLC license may "engage in any trade, business or activity for which a license is required without such license." The penalty grows $100 per day while the activity continues, and TLC can order the business to stop and the premises sealed. If you had a complete license application on file before the notice, the stop and seal orders are paused while it is pending.

What the law says

Admin Code §19-528(a): "It shall be unlawful for any person required to be licensed pursuant to the provisions of this chapter to engage in any trade, business or activity for which a license is required without such license."

§19-528(b) then gives TLC three tools "in addition to the enforcement procedures set forth in section 19-506," after notice and a hearing:

1. Fines of $100 per violation per day, "for each and every day" of the violation.
2. An order to discontinue the activity at the premises.
3. An order sealing the premises, but only if they are "primarily used for such activity."

TLC's rule chapters connect to this law. Every driver, vehicle and base chapter says unlicensed activity "specifically includes the activities listed in §19-506 and §19-528 of the Administrative Code." The chapters for taxicab agents (63) and taximeter businesses (64) define unlicensed activity by reference to §19-528 alone.

Who might receive it

• A dispatch office or base operating without (or after losing) its TLC base license.
• A business acting as a taxicab agent or broker without the license.
• A taximeter business working without its TLC license.
• A licensed business whose license expired and was not renewed.

Individual drivers usually face §19-506 charges instead. If your problem is signs or ads saying "taxi" or "limo," see §19-506(c)(1).

How the orders work

Other rules in the section:

• Removing a seal without authority "shall be a misdemeanor" (§19-528(g)).
• Contents of sealed premises must be reclaimed. If not reclaimed within 90 days, they are subject to forfeiture after notice and a court decision, and may be sold (§19-528(h)).
• Pending application stay. Stop and seal orders are stayed for anyone who submitted "a full and complete application in proper form and accompanied by the requisite fee" before the notice was served, while the application is pending (§19-528(d)). The stay applies to the orders, not to the daily fines.

How 19-528 differs from 19-506

Both sections fight unlicensed activity, but they aim at different targets:

A business can face both. A base that dispatches unlicensed cars could see §19-528 for the base and §19-506 charges for the vehicles and drivers.

Staying licensed

Most §19-528 problems start with a lapse: a renewal sent late, a fee unpaid, or a change of address or ownership never reported. Put every license expiration date on your calendar, renew early, and keep proof of filing. If TLC tells you something is missing, answer within the time stated. If you get a notice, the fine keeps adding up each day, so stopping the activity or getting licensed quickly limits the cost. If you owe fines, see paying TLC fines.

How often it appears

This code is rare, but 2026 already has 83 summonses, more than the previous four years combined. The data doesn't say which businesses or why. If you run a TLC-licensed business, it is a good moment to check that every license is current.

Documents to gather

The hearing

The law requires "notice and a hearing" before TLC can fine you or issue a stop or seal order. TLC summonses are heard at OATH. Hearings are usually by phone or by written defense online if eligible; for an in-person hearing, TLC's summons page says to email LiveHearings@oath.nyc.gov at least 5 business days before the hearing date. A business is usually represented by an owner, officer or lawyer. Bring the license records and the dates, because the number of days of unlicensed activity drives the fine.

Points to discuss with your lawyer

General information only:

• Does the activity need a TLC license at all? That depends on what the business actually does.
• How many days? The fine is per day, so the start and end dates matter.
• Is the premises "primarily used" for the activity? If not, sealing should not apply.
• Was an application pending before the notice?

See also the enforcement topic hub and base affiliation rules.