Yes, you can advertise your own services on your minibuses when they are operated using section 19 permits if these services are not operated for profit, this is because section 19 permits cannot be used ‘with a view to profit nor incidentally to an activity which is itself carried on with a view to profit’.
Commercial Advertising or Sponsorship
Section 19 permit vehicles:
As a vehicle operated using a section 19 permit cannot be used ‘with a view to profit nor incidentally to an activity which is itself carried on with a view to profit; then care has to be taken when considering commercial advertising or sponsorship on your vehicles. These types of deals are common these days and lawyers for the Department for Transport have clarified that it is the relationship between the permit bus operation and the sponsor that must be taken into account when deciding whether the requirements of ‘with a view to profit nor incidentally to an activity which is itself carried on with a view to profit’ are met.
The purpose of section 19 as a whole is to enable certain types of non-commercial service to be operated without the need for an operator’s licence. For example, a section 19 service supported by a supermarket, could not provide a service to the store because the use of the bus would be incidental to a profit-seeking activity. However, other types of sponsorship unconnected with the operation of the vehicle may not violate section restriction. Examples would be a vehicle supplier or manufacturer donating vehicles in return for the operator carrying their sponsorship details on the vehicle, or a vehicle carrying general advertising (e.g. of commercial products) unconnected with its operation. In both cases, the operation of the permit vehicle is independent of the sponsors or advertisers, who only gain a fringe benefit from the display of their name or advertising message.
Section 22 permit vehicles:
The rules which enable section 22 permits contain no restrictions on the use of commercial sponsorship or advertising.
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