Notice to Owner sent more than 6 months after the ticket

After a parking ticket (PCN) has been fixed to your vehicle or handed to you by a civil enforcement officer, the council must serve the 'Notice to Owner' - the formal demand sent to the vehicle's registered keeper - within six months. In England the limit is the Civil Enforcement of Road Traffic Contraventions (Approved Devices, Charging Guidelines and General Provisions) (England) Regulations 2022, regulation 20(2) and regulation 20(4)(d): a notice to owner may not be served after the expiry of the period of 6 months beginning with the relevant date, which in the ordinary case is the date the penalty charge notice itself was served. Serve it later and the council cannot use it to hold the registered keeper liable; the late service is a procedural impropriety on the part of the enforcement authority, which is a listed ground of representation under the Civil Enforcement of Road Traffic Contraventions (Representations and Appeals) (England) Regulations 2022, regulation 5(4)(f). This ground addresses England. Wales has its own regulations for the same rule, and this ground does not plead them.

Legal basis

The Civil Enforcement of Road Traffic Contraventions (Approved Devices, Charging Guidelines and General Provisions) (England) Regulations 2022 (SI 2022/71), regulation 20(2), regulation 20(1), regulation 20(4)(d) and regulation 1(4). Regulation 20(2) provides that 'A notice to owner may not be served after the expiry of the period of 6 months beginning with the relevant date'. Regulation 20(1) allows an enforcement authority to serve a notice to owner only where a penalty charge notice has been given under regulation 9 and the 28-day period specified in it for payment has expired without payment, and regulation 20(4)(d) fixes the relevant date, in the ordinary case, as 'the date on which the relevant penalty charge notice was served under regulation 9'. Late service is put to the authority by representations under the Civil Enforcement of Road Traffic Contraventions (Representations and Appeals) (England) Regulations 2022 (SI 2022/576), regulation 5(4)(f) - 'there has been a procedural impropriety on the part of the enforcement authority'. Territorial scope: regulation 1(4) applies SI 2022/71 in England only, and its Greater London carve-out at regulation 1(5) covers bus lane, London lorry ban and moving traffic contraventions, not parking, so a London parking penalty charge notice is inside this regime. Wales operates its own regime: the Civil Enforcement of Road Traffic Contraventions (General Provisions) (Wales) Regulations 2013 (SI 2013/362), regulation 19(1), carries the same six-month rule, and this ground does not plead it. Both instruments are made under Part 6 of the Traffic Management Act 2004 (civil enforcement of traffic contraventions). Traffic Management Act 2004 Schedule 7, paragraph 1 is NOT relied on: it is a definition provision, construing what counts as a parking contravention, and it imposes no time limit.

How to identify this in your case

Find the date the original parking ticket (PCN) was served - for an officer-issued ticket that is the date it was fixed to the vehicle or handed to you - and then the date printed on the Notice to Owner. If more than six months separate the two, the notice was served outside the statutory window. Two checks before using this ground: the ticket must be a council PCN given by a civil enforcement officer, because a postal PCN sent straight to the registered keeper from camera evidence is served on the owner already and has no separate Notice to Owner stage; and the council must be in England, because Welsh authorities enforce under their own regulations.

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 Representations Team, Re: PCN [NUMBER] — Notice to Owner [REF] I formally challenge the validity of this Notice to Owner. Under the Civil Enforcement of Road Traffic Contraventions (Approved Devices, Charging Guidelines and General Provisions) (England) Regulations 2022 (SI 2022/71), regulation 20(2) and regulation 20(4)(d), a notice to owner may not be served after the expiry of the period of 6 months beginning with the relevant date, which in the ordinary case is the date on which the penalty charge notice was served under regulation 9. The penalty charge notice was served on [DATE]. The Notice to Owner was not served until [DATE] — a period of [X months and Y days], which is outside that six-month period. The Notice to Owner was therefore not validly served and cannot be relied on to pursue me as the registered keeper of the vehicle. That is a procedural impropriety on the part of the enforcement authority within the Civil Enforcement of Road Traffic Contraventions (Representations and Appeals) (England) Regulations 2022 (SI 2022/576), regulation 5(4)(f). I request cancellation of the Notice to Owner and of the penalty charge. Yours faithfully, [NAME]

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Sources

The Civil Enforcement of Road Traffic Contraventions (Approved Devices, Charging Guidelines and General Provisions) (England) Regulations 2022 (SI 2022/71), regulation 20(2) and regulation 20(4)(d) - a notice to owner may not be served after the expiry of the period of 6 months beginning with the relevant date, which in the ordinary case is the date the penalty charge notice was served.
The Civil Enforcement of Road Traffic Contraventions (Representations and Appeals) (England) Regulations 2022 (SI 2022/576), regulation 5(4)(f) - procedural impropriety on the part of the enforcement authority, as a ground of representation.
Traffic Management Act 2004, Part 6 (civil enforcement of traffic contraventions) - the enabling Act for both instruments.