Make a Representation

If you want to challenge a Penalty Charge Notice (PCN), you can make a Representation to TfL.

On this page:

Who can apply
When to apply
How to apply
TfL's response
Grounds for Representation
Mitigation and discretion

Who can apply

PCNs are normally sent to the registered keeper of a vehicle as per the records of the Driver and Vehicle Licensing Agency. They may also be issued to the nominated hirer or leasee of a vehicle if a valid hire agreement is provided by the registered keeper.

The person or organisation named on a PCN must make the Representation, even if they were not the driver. Note:

The registered keeper can make a Representation on behalf of a third party
We will not consider a Representation from a third party unless the registered keeper provides us with written authorisation
If you have been passed a PCN by the registered keeper and wish to challenge it, have them write in on your behalf or provide you with written authorisation to submit with your Representation
If the registered keeper is a company and you are making a Representation on behalf of the company, please indicate your position and authorisation within the company when making your Representation
We will always advise the registered keeper of the outcome of any investigation

When to apply

Representations must be received by TfL within 28 days of the date of service of a PCN. We do not have to consider any Representations received outside the 28-day period.

If you are prevented from sending us your Representation within 28 days, we will use our discretion and may still consider it. You must provide supporting evidence to show what delayed you (eg proof of illness or holiday).

Once we receive your Representation, the PCN will be frozen until we have investigated it and written back to you.

How to apply

Representations must be made in writing by the person or organisation named on the PCN (even if that person was not the driver). The easiest option is to complete the Representation section of the PCN. Please remember to:

If applicable, indicate on which ground you wish to make the Representation
Use the space provided to explain relevant details. If you need more space please attach additional sheets of paper, remembering to write the PCN number on each sheet
Enclose supporting evidence
Sign and date the Representation
Ensure it is received within 28 days of the date of service of the PCN
Send it to:
Low Emission Zone
P O Box 4784
Worthing
BN11 9PU

TfL's response

When we have considered your Representation, we will write back to you with our response. You will be sent either a Notice of Acceptance or a Notice of Rejection.

Notice of Acceptance
This means you are no longer liable for the PCN

Notice of Rejection
This means we have assessed your Representation against accepted grounds and considered any mitigating circumstances, and believe you are still liable for the PCN.

At this stage, we will explain why you are still liable and how much you must pay. If applicable, we will also tell you about your right to appeal to an independent adjudicator.

We may ask you for additional information. If this happens, please return the information within the time stipulated.

Not paying at this stage will mean an increase in the amount you owe and enforcement action continuing. Please do not do nothing at this stage.

Grounds for Representation

A Representation may be made on one of six grounds. If none of these applies to your situation, you can state the reasons why you believe you are not liable for a Penalty Charge Notice (PCN).

Each Ground for Representation is defined by Parliament in the governing regulations. The information we provide about each ground, the evidence you need to provide and the circumstances that are applicable is for guidance only. It does not affect your right to make a Representation

Ground one
I was not the registered keeper of the vehicle at the time the PCN was issued
Ground two
I paid the Low Emission Zone (LEZ) charge due for the vehicle used on that date, in the time and manner required by the LEZ scheme
Ground three
No Penalty Charge is payable (eg I did not enter the LEZ).
Ground four
The vehicle was used or kept without my consent (eg it was stolen)
Ground five
The Penalty Charge exceeds the amount payable in the circumstances of the case (eg I have been requested to pay a Penalty Charge of a higher amount than detailed in the regulations).
Ground six
We are a vehicle hire firm and the vehicle was hired under an agreement at the time and the person liable signed a statement of liability for any resulting Penalty Charges.

Mitigation and discretion

If none of the six grounds are applicable, you can still make a Representation to TfL. If you explain your circumstances, we will consider any mitigating circumstances and use our discretion in reaching a decision.

We will not accept the following explanations:

Forgetting to pay the charge without any mitigating circumstances for doing so
Not knowing how to pay the charge
Not meaning to enter the LEZ or entering it as a result of getting lost
Disapproval of the LEZ scheme
Not knowing about the LEZ