How many violations put my Konzession at risk?

There is no fixed number. BOKraft decides on the full picture. Repeat violations over twelve months without a clear response are the classic reason for non-renewal. What matters is not the number. What matters is proof that you actively detect, log, and act.

Is it a violation if the driver picks up a new trip in the city centre?

No. The new order cancels the return duty, as long as it came in right after the last trip. It only gets critical when the driver actively waits before the new order arrives. That waiting time is the violation. And you can reconstruct exactly that from GPS and Uber/Bolt logs.

What exactly is the Betriebssitz (place of business)?

That is the address of your company as written in the Konzession. After every trip without a follow-up order, the car has to go there. Or to an area the authority accepts as equal. What ‘immediately‘ means is not clearly defined. Rule of thumb: no detour, no unneeded standing time.

Spotting Rückkehrpflicht violations before BOKraft does

The one rule that costs many Konzessions

§ 49 (4) PBefG (that is the German passenger transport law) sits on every Konzession decision. But few rental car bosses read it carefully.

The sentence says: A rental car must return to its place of business right after every trip. Unless a new order has already come in.

What does that mean? No waiting in the city centre. No parking at the airport without a booking. No cruising around, hoping for the next Uber ping.

Taxis do not have this rule — taxis may wait at stands. Rental cars are not allowed. And because Uber and Bolt in Germany run almost only with rental cars, Rückkehrpflicht is the one rule that can cost a well-run business its Konzession.

Why BOKraft (that is the transport authority) looks here

Because this rule is what makes the difference between taxi and rental car. Without it, the rental car market would be a second, unregulated taxi market.

The authorities take that seriously. BOKraft, Ordnungsamt, and sometimes the state ministry. At Konzession renewal, they do not look for single violations. They look at the full picture from the last twelve months.

What BOKraft usually checks:

GPS records of the cars if you have them (Samsara, Fleetio, and many systems log every move).
Uber and Bolt trip logs with exact times and places.
Match with the place of business: did the cars really go back to your registered address after their trips?
Response to violations: did you act or ignore it?

The last point is the most important. A business with ten violations plus clear response (driver coaching, warning, suspension) has a stronger case than a business with three violations and no visible action.

Why it happens all the time on Uber

Uber and Bolt do not punish empty cars. On the contrary: a car waiting in a hot zone gets the next order first. The rewards are built against the return rule.

Drivers who want to hit their hourly target quickly learn where waiting pays off. And because you cannot watch drivers day and night, waiting quietly becomes the default.

The problem is not one single violation. The problem is: nobody counts. You only hear about the violations when BOKraft names them. By then it is usually too late.

How to make violations visible

The only reliable way: automatic detection from data you already have. GPS and Uber/Bolt logs exist — they are just not combined. When you match both per car and per day, you see in seconds:

Trip A ended at 14:22 in Berlin-Mitte.
The car circles around Kurfürstendamm until 15:07.
Trip B starts at 15:11 in Charlottenburg.

Result: between 14:22 and 15:07 there was no order. The driver did not return to the place of business. That is a violation. With timestamp. With GPS location. With driver name.

That is exactly what BOKraft would reconstruct in an inspection.

If you see this every week inside your office, you can act — before BOKraft does. Coach the driver. Log a warning. Suspend on repeat. And all of that is logged in turn. That is the paper trail BOKraft wants to see.

What you can do concretely

Keep a rolling twelve-month list. Which drivers, how many violations, what response?
Coaching before punishment on the first case. Drivers often do not know that waiting is a violation.
Log from the start. Not only when the inspection is announced. Building proof after the fact looks made-up.
Escalate repeats clearly. Warning, suspension, and in the worst case separation. That consequence is exactly what BOKraft wants to see.

Rückkehrpflicht is not the end of your Uber and Bolt work. It is the frame it has to fit in. Bosses who actively steer the frame keep their Konzession — and their business with it.

Why this matters now

Inspections have become harder in the last two years. More and more cities have their own teams that only check rental cars. Berlin, Hamburg, Munich, Frankfurt, and Cologne do hundreds of checks every year.

Anyone not logging today has no chance tomorrow. Fahrly Compliance gives you the proof in one click. You export the last twelve months as a PDF and hand it in at the inspection. Time needed: five minutes instead of half a day of panic.