The Last-Mile Risk: Illegal Ground Transport and Duty of Care

Your traveler lands at O’Hare after a transatlantic flight. It’s 11pm. They’re tired. As they exit customs, a man approaches holding a phone displaying their name, a car brand, and a fare. Looks organized. Feels legitimate. They get in.

The driver is unlicensed. There is no verified insurance. No trip record in any system your team can access. If something goes wrong on the way to the hotel - an accident, a robbery, a medical emergency - you have no visibility and no contractual relationship with the operator. Your duty of care coverage just developed a hole large enough to drive a car through.

This is the scenario a new national study is now placing on the desk of every corporate travel manager. Presented at the Global Business Travel Association (GBTA) Convention in Chicago on August 4, 2026, the preliminary findings from the National Limousine Association (NLA) and the University Transportation Research Center (UTRC) at The City College of New York make a pointed case: illegal ground transportation has evolved from curbside hustling into a technology-enabled, organized risk that sits squarely inside your duty of care blind spot.

What the Study Found

The NLA-UTRC research examined 17 major U.S. aviation and business travel markets: Atlanta, Boston, Charlotte, Chicago, Dallas/Fort Worth, Denver, Detroit/Fort Wayne, Houston, Las Vegas, Los Angeles, Miami, Minneapolis/St. Paul, New York, Orlando, Phoenix, San Francisco, and Seattle. These are not edge cases. They represent the core of American corporate travel activity.

The key findings:

• Illegal for-hire activity has migrated online. Operators now use professional websites, social media accounts, and private messaging groups to mimic licensed car services. The presentation is deliberate and increasingly convincing.
• Airports, hotels, conventions, and major events are the primary hotspots. Business travelers are the target demographic precisely because of the frequency and predictability of their movements.
• Off-platform and unlicensed trips fall outside standard insurance and platform protections. When something goes wrong, there is often no actionable trail.
• Driver screening, vehicle inspections, and reliable trip records are absent. Passengers frequently have no practical way to verify who they are riding with.
• Unlicensed operators avoid licensing, insurance, tax, and airport-access costs required of legitimate providers - which lets them undercut on price and attract travelers booking outside managed programs.

The preliminary legal review also identified at least seven states with laws expressly criminalizing rideshare driver impersonation: California, Colorado, Connecticut, Florida, North Carolina, South Carolina, and Tennessee. The fact that such laws were deemed necessary - and exist in only a minority of states - signals how normalized the practice has become.

The study builds on 2025 research the same team conducted in New York and New Jersey, where illegal operators had already built organized digital dispatch networks with customer-facing apps, coordinated availability, and social media marketing that made them functionally indistinguishable from licensed providers to the average traveler.

This is Not a Developing-Market Problem

There is a default assumption in corporate travel risk that ground transportation is a developing-market concern. Vet your provider in Nairobi. Use a pre-approved driver in Karachi. At O’Hare or SFO, the regulatory environment handles it.

That assumption is the vulnerability.

Brett Barenholtz, President of the NLA, was blunt at the GBTA Convention: “Duty of care does not end when an employee leaves the airport terminal. Companies need confidence that the provider, vehicle and driver transporting their people are safe, properly licensed and fully insured. As illegal operators become more sophisticated, verification must keep pace.”

Matthew Daus, UTRC Transportation Technology Chair and lead researcher, framed the structural shift: “Illegal transportation is no longer only a curbside problem. It is a technology, jurisdiction and public-safety issue requiring coordinated enforcement, verification tools and updated laws.”

What makes this particularly hard to address is that the deception layer is intentional and calibrated. These are not operators who look obviously informal. They are operators who have studied what legitimate services look like and replicated the signals - professional websites, SMS confirmation flows, name placards at arrivals. The business traveler screening for safety cues will often fail to find them.

The Four Things You Lose

Your duty of care during a business trip does not pause between flight segments. It applies continuously from departure gate to hotel room, and ground transportation is part of that chain.

When an employee uses an unlicensed operator, four specific protections break down simultaneously.

Traveler visibility. Most travel risk platforms track itineraries built through approved booking channels. A trip booked off-platform - through a WhatsApp group, a private website, or a cash arrangement at arrivals - generates no data. If a crisis occurs and you need to locate and contact all travelers in a market, this person is invisible to your operations center.

Commercial insurance coverage. Unlicensed operators routinely lack the commercial vehicle insurance required for hire-and-reward operations. A collision or injury can result in no viable insurance claim. The question of who bears liability becomes complicated quickly, and the answer is rarely the unlicensed driver.

Driver vetting. Licensed providers in all 17 markets studied are required to pass background checks and vehicle inspections. Unlicensed operators skip this entirely. You have no ability to verify who was transporting your employee.

Incident response capability. A licensed provider has accountability structures - regulatory oversight, licensing records, operator contacts. When something goes wrong with an unlicensed operator, there is frequently no entity to engage with and no documentation to produce if the matter becomes a claim or litigation.

The Legal Exposure

UK organizations operating under health and safety legislation, and employers in Australia subject to Work Health and Safety law, are in particularly exposed territory. Courts in both jurisdictions have interpreted “at work” to include the full duration of a business trip. The ground segment is not exempt, and ignorance of the booking channel is not a defense.

For U.S.-based organizations, the picture is different. A Travel Weekly analysis published last week argued that no U.S. court has held that employers have a statutory duty to warn traveling employees about ground transportation risks domestically - and that the legal concept of a “duty of care” for business travel in the U.S. is largely moral rather than legally enforceable in the absence of specific industry regulations or negligence claims. That analysis is accurate as far as the case law currently stands.

But “currently stands” is doing a lot of work in that sentence. The NLA-UTRC study is evidence entering the professional record. Legal precedent in novel areas typically develops after enough incidents accumulate to make a negligence case tractable. Corporate travel programs that document a deliberate decision to ignore ground transportation risk - or that fail to document any decision at all - are building exposure.

Why This Gap Persists

Three structural factors keep this vulnerability open in most programs.

The booking is often invisible. Travelers arrange ground transport through channels that bypass the managed travel program entirely - direct hotel bookings, personal ride-hailing apps, local recommendations, or an unsolicited approach at arrivals. Unless your program explicitly captures ground transport data, it never enters your risk picture.

The economics cut against compliance. Unlicensed operators are cheaper. In markets where travelers are cost-conscious or booking on personal accounts for later expense submission, the difference between an approved car service and an off-platform option can feel like a rounding error to the traveler and is invisible to the program.

It has historically lived in the wrong risk category. For most North American travel programs, ground transportation has been treated as a logistics convenience question, not a safety and duty of care question. The GBTA study is arguing - with data from 17 markets - that this categorization is wrong.

Closing the Gap

The UTRC and NLA recommendations for corporate travel managers are practical and implementable without waiting for regulatory reform.

Mandate approved providers and booking channels explicitly. Most travel policies are soft on ground transport. “Use approved providers” reads very differently than “the following approved car services apply in these markets, and off-platform bookings require advance security team authorization.” Be specific.

Include ground transport in your vendor sourcing and risk reviews. When you audit your travel supplier relationships, verify that ground transport suppliers hold the correct licensing, commercial insurance coverage, and airport operating authorization for each market where they operate.

Build independent verification into the exception process. Travelers will occasionally book outside the approved list. Establish a lightweight check for those cases: confirm the company name, driver details, and vehicle through independent channels before the trip happens.

Educate your travelers on what a legitimate booking looks like - and what it does not. A professional website is not evidence of licensing. A name on a phone display is not verification. Give your travelers a simple framework: if the booking channel was unsolicited, if there is no confirmation through the approved tool, or if the transaction is cash-only, treat it as unverified and contact your program manager.

Extend tracking and emergency communications to cover ground transport legs. If your travel risk platform does not capture ground transport itinerary data or cannot send alerts and SOS during the ground segment, raise that with your vendor. It is a gap.

We covered the broader road safety exposure for corporate programs in an earlier playbook - see Business Travel Road Risk: A Duty of Care Playbook for the route risk, fatigue, and remote site elements. The illegal operator problem is a distinct layer that sits on top of that exposure. Both require attention.

What Comes Next

The NLA-UTRC study is calling for stronger regulatory authority, escalating penalties, coordinated enforcement at airports and major events, searchable licensing databases, and updated laws addressing digital dispatch networks and impersonation. That is the right direction. It will also take time.

In the meantime, corporate travel programs are the practical backstop. Your approved vendor list, your booking channel requirements, and your traveler education are the enforcement mechanism that exists today.

At HAAVYN, continuous traveler visibility runs through the ground segment when trips are booked through integrated channels. SOS, real-time alerts, and check-in tools remain active regardless of transport mode. That kind of end-to-end coverage is exactly what the NLA-UTRC findings are calling for. If you want to understand how HAAVYN closes the ground transport visibility gap for your program, book a call with our team.

The GBTA Convention on August 4 put the illegal ground transport problem on the professional record. Your program’s response to it is now a documented choice either way.