OUR RESPONSE TO THE MINISTRY OF CULTURE AND TOURISM'S DECISION ON TÜRSAB VEHICLE LICENSE PLATES

Issue     : 2024.03/07810
Subject : Audit of Travel Agencies

T.R.
MINISTRY OF CULTURE AND TOURISM
General Directorate of Investment and Enterprises

Interest : Your letter dated 15.10.2024 and numbered 5811806.

In the audits carried out by the Governorships (Provincial Directorates of Culture and Tourism) for the package tour, tour and transfer services of travel agencies; the documents that must be kept in the travel agency official in package tour and tours and in the transfer staff in transfer vehicles and must be shown to the auditors are listed in Articles 40 and 41 of the Travel Agencies Regulation. The issue of "TÜRSAB Vehicle License Plate", which is given by the Association of Turkish Travel Agencies (TÜRSAB) upon the request of travel agencies and kept in a way that can be seen from the outside at the front of the vehicle during audits, is also specified in both articles of the same regulation. In the Law No. 1618 on Travel Agencies and the Association of Travel Agencies and the Regulation on Travel Agencies and the Regulation on the Association of Travel Agencies enacted on the basis of this Law, there is no regulation requiring the renewal of the “TÜRSAB Vehicle License Plate” by the Association every year or at certain intervals and the use of renewed plates by travel agencies. In this context, it is reported that in the inspections to be carried out by the Governorships (Provincial Directorates of Culture and Tourism), if the “TÜRSAB Vehicle License Plate” issued by the Association is found, regardless of whether it is renewed during the control of the documents specified in Articles 40 and 41 of the Travel Agencies Regulation, the existing license plate will be accepted.

          It is felt necessary to clarify some of the issues in the article and to remind some information. The regulation regarding the document referred to as TÜRSAB Vehicle License Plate does not consist of Articles 40 and 41 of the Travel Agencies Regulation, it is a duty regulated in paragraph (r) of Article 5 of the Association of Travel Agencies Regulation titled Duties of the Association. Accordingly, it is stated as the duty of our Association to “issue the vehicle identification certificate showing which travel agency the vehicles used in travel agency activities belong to ”. The application regarding the documents expressed as TÜRSAB Vehicle License Plate in the Travel Agencies Regulation and the vehicle identification certificate in the Association Regulation has become the basis of professional practice that has been continuing uninterruptedly since 1994, and has been adopted and accepted as a basis by the supervisory authorities and staff. The most basic function of this document is to indicate that a vehicle in traffic is currently carrying out a tour or transfer, which is a travel agency activity. As it is known, owners and operators of vehicles engaged in touristic transportation activities are not obliged to be travel agencies, but the tour or transfer must be carried out on behalf of a travel agency. Travel agencies carry out tour and transfer activities with vehicles in accordance with the Transportation Legislation and based on the contract they will make with transporters. The TÜRSAB Vehicle License Plate is used on the windshield of the vehicle to indicate to the police and other officers who will carry out activity inspections which travel agency activity is currently in charge of that vehicle. It is important for an effective inspection to distinguish between travel agencies and non-travel agencies by focusing the inspection on vehicles without these license plates. The presence of the license plate shows that the activity belongs to the travel agency, but it also shows whether the travel agency is active, whether it has authorization for this activity, and enables the determination of the content of the activity through the electronic monitoring system operating in connection with this license plate. Therefore, the information contained in the license plate must be up-to-date.

          As it is known, the fact that travel agencies have left their license plates with transporters, that they were travel agencies in the past years but have ceased their activities, and the prevention of the use of travel agency license plates by unauthorized persons in tours and transfers are among the most important problems that are being struggled to solve today. UKOME decisions in metropolitan cities, road route certificates, U-ETDS system in intercity activities are important practices carried out by the public for inspections in this field. The renewal of the vehicle license plates of travel agencies every year is an important factor in preventing unlicensed activities with vehicle license plates scattered among transporters, as well as the software developed by our Association, even in urban transportation, just like the U-ETDS system, thanks to the activation of information about the activity carried out (starting and ending the activity), healthy inspections can be carried out regarding tours and transfers.

          TÜRSAB Vehicle License Plate is renewed every year and the information of the travel agency with this license plate is updated, and thanks to the electronic chip embedded in the license plate and invisible from the outside, all information subject to inspection can be accessed quickly and securely through the license plate. Determining the number of license plates that travel agencies should have depending on their capacity and meeting the license plate demand accordingly enables the use of another preventive inspection feature to prevent the illegal activity called “license plate renting”. In order to combat this situation, which is very widespread in the public opinion and increases undocumented activity, our Association is able to combat undocumented activity by issuing the number of license plates in accordance with the proven capacity of the travel agency each year. For this purpose, the officials within the Association spend a great deal of time.

          The TÜRSAB Vehicle Plate makes it clear that the information is up-to-date annually with its color changing every year, as well as enabling instant activity control with license plate activation in the electronic information system of our Association, and thanks to the chip it contains, it ensures that the inspection is carried out without disturbing the tourists during the activity.

          In the audits carried out through the TÜRSAB Vehicle License Plate, a total of 359,330 vehicle activity audits were carried out in 2022, 2023 and 2024, 6730 undocumented activities were detected and legal action has been taken against them until today.

          It should not be forgotten that the TÜRSAB Vehicle License Plate does not belong to a vehicle or transporter, and if it is not issued by the above-mentioned method or does not carry the technical specifications, it will lose its feature of being a document that is always valid once it is received, showing the competence of the travel agency for tour and transfer activities. Today, the transformation of the TÜRSAB Vehicle License Plate, which is the only element that distinguishes the travel agency activity from taxi and other non-touristic transportation activities, into an element that is considered sufficient once received, without knowing and considering the technical features and functions, will make it impossible to control the tour and transfer activity.

          If the TÜRSAB Vehicle Plate, which has the features and functions described above, is defined with the license plate obtained in any way in any period, it is obvious that road inspections cannot be carried out on vehicles operating with more than ten thousand old TÜRSAB Vehicle Plates, which are currently in the past years and are owned by people who carry out transportation without a travel agency. As a result of the undocumented activities that will occur with the elimination of the most important control element in tourism, it is clear that not only the quality of service will decrease, but also the country's tourism will be damaged, accidents will increase, and tax loss will occur with the increase in activities that are uninsured, uninvoiced, unprogrammed, unguided, against consumer rights.
TÜRSAB Audit Unit will be limited to the establishment and digital environments due to the fact that the audit staff and vehicle expenses, which constitute a major investment and expense for our Association, cannot be met and the most important audit basis will lose its function. In this case, we remind you that the responsibility for the chaos and undocumented activities will belong to your authority.

          We inform you that as of October 17, 2024, our Association's inspections regarding tours and transfers have been terminated due to actual impossibility as of October 17, 2024, with your instruction to abandon the practice of renewing TÜRSAB Vehicle Plates every year, which has been continuing since 1994.

          If the procedures and measures to be taken by the Ministry to prevent and control the increase in undocumented activities due to the lack of supervision that will occur in line with your instruction are notified to our Association, the necessary announcement will be made to our members.

          We submit the subject for your information.

Sincerely,

Çağla ELHAN
Secretary General