Published: 30 October 2026Last reviewed: 30 October 202610 min read
In short: a forklift, a telehandler, a backhoe or a self-propelled aerial platform becomes a vehicle the moment it enters the street, even to cross the road or drive 200 metres to the next site. The Portuguese Highway Code calls them "industrial machines" (article 109) and requires four things: a driving licence of the right category (B up to 3,500 kg gross weight, C or D above), an IMT registration with a red plate (Decree-Law 107/2006), third-party motor insurance and an amber beacon switched on. Driving an unregistered machine costs €600 to €3,000; driving outside your licence category €500 to €2,500. The alternative, and in practice the usual one, is to move the machine on a trailer or a truck.
What an "industrial machine" is under the Highway Code
Article 109(2) of the Highway Code defines an industrial machine as "a vehicle with a propulsion engine, two or more axles, intended for construction or industrial work and which only occasionally travels on public roads". It is light up to 3,500 kg gross weight and heavy above. "Only occasionally travels" is not an exemption: it means the machine was not built for the road, but when it is on the road the vehicle rules apply.
This covers forklifts, telehandlers, wheel loaders, backhoes, wheeled excavators, rollers, mobile cranes, dumpers and self-propelled aerial work platforms. Agricultural and forestry tractors and machines are a separate family (article 108) with their own licence and rules, and the Code does not use the term "special vehicle": it appears only in the abnormal-load regime, explained in our guide to transporting heavy machinery.
Pedestrian-operated machines (a push-around scissor, a small walk-behind roller) are excluded: they need no plate or licence, but they also cannot be driven on the road as vehicles.
Which driving licence you need
The rule is article 3(4) of the Driving Licence Regulation (Decree-Law 138/2012 as rewritten by Decree-Law 102-B/2020, in force since 8 January 2021). Decree-Law 40/2016, often quoted in connection with machines, mostly dealt with licence validity and medical checks; its only machine rule is the one allowing holders of a type I agricultural tractor licence to drive industrial machines up to 2,500 kg.
| Licence | What it allows you to drive |
|---|---|
| B | Light industrial machines (gross weight up to 3,500 kg); type I agricultural vehicles; type II only after training (restriction 792) |
| C or D | Heavy industrial machines (over 3,500 kg); type I and II agricultural vehicles; type III after training (restriction 793) |
| BE | Tractor with trailer or towed machine, combination up to 6,000 kg |
| C1E or D1E | Machine of 3,500 to 7,500 kg with a trailer over 750 kg, combination up to 12,000 kg |
| T (type I) | Industrial machines up to 2,500 kg |
| T (type II) | Type I agricultural vehicles, light agricultural machines and tractor-carriers up to 3,500 kg |
| T (type III) | Type I and II agricultural vehicles |
Two points catch people out. First, a B licence only covers light machines: a forklift with 2.5 t capacity normally weighs 4 t, and a telehandler 7 to 12 t, so on the road they need a C licence. Second, the driving licence and the operator training certificate are different and cumulative: the licence is for public roads, the training is for operating the machine safely anywhere. We explain training in the forklift licence guide and the excavator operator guide.
For agricultural tractors, B or C licence holders who want to drive type II or III agricultural vehicles must attend the COTS course (or UFCD 9596) and have the restriction entered on their licence, for €30. The deadline has been extended for the third time, to 1 August 2027 (Order 9675-C/2026). Old municipal or IMT agricultural driving licences remain valid and become category T on renewal.
IMT registration: when it is mandatory and how to apply
The Industrial Machine Registration Regulation (Decree-Law 107/2006) applies to all industrial machines, self-propelled or towed, with a gross weight above 300 kg, except pedestrian-operated ones. Registration is mandatory to circulate on public roads; a machine that never leaves the site or the warehouse does not need it.
Annex I of the regulation classifies machines with a two-letter code shown on the certificate:
| Code | Machine | Examples |
|---|---|---|
| EM | Forklift | Counterbalance forklifts; in practice also telehandlers, depending on type approval |
| PL | Aerial platform | Self-propelled platforms for lifting people or loads |
| RE / ES | Backhoe / Excavator | Backhoe loaders, wheeled excavators |
| PC / TI | Wheel loader / Industrial tractor | Loaders, industrial tractors and tool carriers |
| UT / AG / CC | Transport unit / Mobile crane / Roller | Dumpers, mobile cranes, compaction rollers |
How to apply. For new machines, apply at an IMT regional office with Form 9 (Modelo 9), the certificate of conformity (COC) or manufacturer's declaration, proof of ownership (invoice) and your ID. The fee is €45 when the machine has national or EU type approval; without approval you must file the complete technical dossier and the fee rises to €160 plus €45. The registration certificate is only issued after the ownership is recorded at the registry office. For imported machines the process is the same with the customs paperwork; see our guide to importing machinery.
Plate. The plate is red and retroreflective, in format VIII (520 × 110 mm) or IX (340 × 220 mm), and its letter shows the circulation class of Annex II, set by design speed (up to or above 40 km/h) and dimensions. Class B, for instance, is for machines without full lighting: daytime only and no tunnels. Class F may not use motorways. Classes C, D, G and H (over 2.55 m wide, 12 m long, 4 m high or 60 t) may only move under a special transit permit, the regime explained in our abnormal-load guide.
Marking the machine. Article 14 of the regulation requires white and red 45° stripes, at least 300 mm wide, on parts projecting more than 1,000 mm to the front or rear or more than 500 mm to the side (forks, booms, buckets). Missing marking: €300 to €1,500 (article 45). When the boom or forks project more than 1,500 mm, article 13 also requires the beacon to be on.
Compulsory insurance, road tax and periodic inspection
Insurance. Decree-Law 291/2007 (article 4) requires third-party motor insurance for any motor vehicle whose driving requires a specific licence. It exempts unregistered agricultural machines and use "in purely agricultural or industrial functions", that is, the machine working on site or in the warehouse. But as soon as it crosses the street it is in traffic: the Coimbra Court of Appeal (judgment of 10 March 2015, case 1533/12.1TBGRD.C1, following the EU Court of Justice's Vnuk ruling) held that a forklift moving on a public road must be insured. Driving uninsured costs €250 to €1,250 for machines (Highway Code, article 150(2)). The company's public liability policy for the site does not replace motor insurance; see our guide to machinery insurance.
Road tax (IUC). The Single Circulation Tax Code only taxes categories A to G (cars, motorcycles, boats and aircraft). Industrial machines are in none of them and so pay no IUC, even when registered.
Periodic inspection (IPO). The IMT inspection schedule covers categories M, N and O and wheeled tractors faster than 40 km/h. Industrial machines are not listed, so they do not go to the inspection centre. This does not exempt them from the periodic checks of Decree-Law 50/2005, which is an employer's duty, not a Highway Code one: see mandatory inspections of platforms and machines.
Rules of the road
- Beacon. Article 23(4) of the Highway Code requires vehicles that stop on the carriageway or move slowly, "including agricultural or forestry tractors and machines and industrial machines", to carry and use amber special warning lights. Without one: €60 to €300.
- Speed. The table in article 27 sets specific limits: registered industrial machines 40 km/h in built-up areas, 70 on other roads and 80 on motorways; unregistered machines 30 km/h outside built-up areas; tractors 30 and 40; agricultural machines 20. Regardless, article 26(4) of Decree-Law 107/2006 limits machines without full night lighting to 40 km/h.
- Motorways. Closed to agricultural vehicles and to any vehicle that by construction cannot exceed 60 km/h (article 72): almost every construction machine. Fine €120 to €600.
- Slow vehicles. Outside built-up areas, on single-lane roads, machines in convoy must keep at least 50 m apart to allow overtaking (article 40). Driving unnecessarily slowly is also an offence (article 26).
- Passengers. Nobody outside approved seats (article 54): €60 to €300 per person and the machine is immobilised. Carrying a colleague standing on the platform or the forks is the most common offence.
- Parking. Industrial and agricultural machines may not park on public roads outside dedicated parks (article 50(1)(g)).
- Documents. The driver always carries ID, licence and insurance certificate (article 85); carrying the machine's registration certificate is advisable too.
- Night and tunnels. Class B machines under Decree-Law 107/2006 travel in daylight only.
- Mud on the road and road closures. The Code has no specific article; cleaning the road and occupying it for machine crossings are governed by municipal by-laws and the works licence. Ask the council when the crossing is regular.
Five practical cases
- Moving a scissor lift 200 m down the street between two sites. It is traffic. The platform is a PL-type machine and would need registration, insurance, a beacon and a driver with a licence (B up to 3,500 kg, C above). Since almost no scissor lift has road type approval, it cannot be registered: the right answer is a trailer or a truck with ramps, even for 200 m.
- Telehandler on a rural road. A heavy industrial machine (7 to 12 t): C or D licence, red plate, insurance, beacon, stripes on the forks, class speed limit and no motorway. Over 2.55 m wide it becomes an abnormal load.
- Forklift crossing the street between two warehouses. Crossing is traffic, as the Coimbra court held. Either register the machine (type EM) and insure it, with a C-licence driver in most cases, or move it by truck. Closing the street "just for a minute" with cones is no substitute for the law.
- Mini excavator: trailer or drive? On a trailer no machine registration is needed; the driver needs B if the combination stays under 3,500 kg (or the trailer under 750 kg), B96 or BE above. Driven on the road it is an ES-type machine needing registration and a B or C licence, and steel tracks on asphalt are generally banned by municipal regulations.
- Tractor with a front loader. An agricultural vehicle (article 108): category T, or B/C with restrictions 792/793 after the COTS course, tractor registration, insurance on the road, beacon and stripes on the loader.
Fines
| Offence | Legal basis | Fine |
|---|---|---|
| Driving a machine outside the licence category | Highway Code, art. 123(3) | 500 to 2,500 |
| Unregistered machine in traffic | Highway Code, art. 117(8) | 600 to 3,000 |
| No compulsory insurance | Highway Code, art. 150(2) | 250 to 1,250 |
| No beacon or beacon switched off | Highway Code, art. 23(6) | 60 to 300 |
| Forks or boom without contrast stripes | Decree-Law 107/2006, art. 45 | 300 to 1,500 |
| Slow vehicle on a motorway | Highway Code, art. 72(3) | 120 to 600 |
| Passenger outside a seat | Highway Code, art. 54 | 60 to 300 per person |
What changed in 2024, 2025 and 2026
- The COTS training deadline for tractors moved from 1 August 2024 to 2025 and then to 1 August 2027.
- Decree-Law 112/2026 (in force since July 2026) changed accompanied learning for the B licence and theory-test translation; nothing changed for machines.
- The digital driving licence in the id.gov.pt app is valid in Portugal; the 2025 EU directive on digital licences and the B licence at 17 only applies once transposed, around 2029 and 2030.
- No new IMT fee order for machines has been published; the registration fee remains the €45 shown by the IMT.
Where Trapézio de Prismas comes in
We are the JLG dealer in Portugal and sell new and used telehandlers and aerial work platforms. When we deliver a machine we hand over the certificate of conformity the IMT needs for registration, and we can take care of fork marking and the beacon. We also carry out the periodic checks under Decree-Law 50/2005 on platforms and telehandlers. If your machine rarely moves, a trailer remains the cheapest option: tell us the machine and we will help you choose.
Sources and legislation
- Código da Estrada, versão consolidada (PGDL)
- Decreto-Lei n.º 138/2012, Regulamento da Habilitação Legal para Conduzir (Diário da República)
- Decreto-Lei n.º 102-B/2020, categoria T e alterações ao Código da Estrada (Diário da República)
- Decreto-Lei n.º 40/2016 (IMT)
- Decreto-Lei n.º 151/2017, formação para condução de veículos agrícolas (Diário da República)
- Decreto-Lei n.º 107/2006, Regulamento de Atribuição de Matrícula a Máquinas Industriais (Diário da República)
- IMT, matrícula de veículos novos: máquinas industriais
- IMT, formação COTS: prazo prolongado até 1 de agosto de 2027
- Decreto-Lei n.º 291/2007, seguro obrigatório de responsabilidade civil automóvel (Diário da República)
- IMT, tipos de inspeções e periodicidade
- Código do IUC, artigo 2.º, incidência objetiva (Portal das Finanças)
- Nota orientadora ANSR, GNR, ACT, IMT e DGADR sobre condução de veículos agrícolas
- Tribunal da Relação de Coimbra, seguro obrigatório e máquina industrial em circulação (acórdão TJUE Vnuk)
This guide is for information only and does not replace the legislation in force or legal advice. When in doubt, contact the Portuguese labour authority (ACT).
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