Company vehicle — keeper is the company, not the named driver

Where the vehicle is registered to a company (Limited, LLP, plc), the keeper for PoFA Sch 4 purposes is the COMPANY, not the named driver — Sch 4 para 2 presumes the registered keeper is the keeper. The operator must give the NTK to a 'current address for service' for the company (Sch 4 paras 8-9): in practice the company's registered office (Companies Act 2006 s.1139) or the address on the DVLA record obtained under Sch 4 para 11. Operators frequently send NTKs to the named driver or a director/employee's home address — that is not a current address for service for the company, so the keeper-liability route fails. Note this defeats KEEPER liability only: the company should not identify the driver (and no one should falsely deny driving), because a named driver can be pursued directly. A sole trader's business is not a separate legal person — if the V5C names an individual, this ground does not apply.

Legal basis

PoFA 2012 Sch 4 paras 2, 8, 9, 11 (keeper definition; NTK to a current address for service; DVLA application); Companies Act 2006 s.1139 (service on companies at registered office)

How to identify this in your case

V5C is in company name; NTK was sent to home address of director/employee; no NTK to registered office.

Sample appeal wording

Before you send this

Deadline. A late submission can be turned down without your argument being read. Check your notice for the deadline and how it is counted.
Paying may end it. Paying can count as accepting the notice and can close a challenge already under way. Part-paying or acknowledging an old debt can also revive a time limit that had expired.
The amount can change. Check what happens to the sum if you challenge — it may be held, re-offered lower, or keep rising, and fees or enforcement can continue meanwhile.
Use the official route. Use the method, recipient and form your notice specifies, with any reference, evidence and signature it asks for. Sent elsewhere, it may not count.
Only say what is true. Do not copy any statement of fact unless it is true for you, and check the legal point still applies. Delete what does not fit. It may be treated as your statement.
Careful what you volunteer. Avoid unnecessary admissions — naming the driver or accepting responsibility can remove arguments. But answer anything you are legally required to answer, and do include the evidence your ground needs.
Keep the record. Keep what you sent, the attachments, any receipt, and the reply. Note the next deadline.

Sample wording to adapt and send yourself — it may not fit your notice or the stage you are at. Replace the bracketed prompts with your own details; leave any case citation as it is.

Dear [OPERATOR], Re: NTK [REF] — Vehicle [REG] The vehicle is registered to [COMPANY NAME], company number [NUMBER]. I am [an employee / director] but I am not the keeper for the purposes of Schedule 4 PoFA 2012. Under paragraph 2, 'keeper' is the registered keeper, which is the company. Under section 1139 Companies Act 2006, valid service on a company is at its registered office, which is [ADDRESS]. Your NTK was sent to my personal address and is therefore not a valid Notice to Keeper. Without valid service of an NTK compliant with Sch 4 paras 8/9, you cannot establish keeper liability under para 4(4). I require: 1. Cancellation of the personal address charge; 2. Erasure of my personal data under UK GDPR Art 17; 3. If you wish to pursue the company, serve correctly at its registered office. The company is then entitled to identify (or decline to identify) the driver. Yours faithfully, [NAME]

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Company vehicle — keeper is the company, not the named driver

Legal basis

How to identify this in your case

Sample appeal wording

Beat It writes this argument automatically

Sources

Related appeal grounds

Next steps