ULEZ charge — hired vehicle, wrong person billed

This ground is for a vehicle-hire firm that received a London ULEZ penalty for a vehicle that was out on hire. The law makes the registered keeper pay, but the penalty moves to the person who hired the vehicle when all of these are true: the vehicle was hired under a written hiring agreement (not hire-purchase) whose original fixed period was less than six months; the agreement contains every particular set by regulations that applies to it; and the person hiring it signed a statement of liability accepting liability for any charges or penalty charges incurred under a charging scheme during the currency of the hiring agreement. If all of those are met, you can ask TfL to transfer the penalty to the hirer by sending the agreement and the signed statement.

Legal basis

Greater London Authority Act 1999 Sch 23 para 13 (charges and penalty charges are paid by the registered keeper, or in prescribed circumstances by a prescribed person); Road User Charging (Charges and Penalty Charges) (London) Regulations 2001 (SI 2001/2285, as amended) reg 6(6): payable by the hirer where the registered keeper was a vehicle-hire firm, the vehicle was hired from it under a hiring agreement, and the person hiring it signed a statement of liability acknowledging liability for "any charges or penalty charges incurred under a charging scheme during the currency of the hiring agreement"; reg 2 gives 'hiring agreement' and 'vehicle-hire firm' the meaning in Road Traffic Offenders Act 1988 s.66 (as does reg 2 of SI 2001/2313): an agreement containing the particulars prescribed by the Road Traffic (Owner Liability) Regulations 2000 (SI 2000/2546) Sch 2, not a hire-purchase agreement (s.66(8)), under which the vehicle is let for a fixed period of less than six months, whether or not that period can be extended (s.66(7)). Road User Charging (Enforcement and Adjudication) (London) Regulations 2001 (SI 2001/2313, as amended) reg 12(2) (the penalty charge notice is served on the registered keeper unless the penalty is payable by another person) and reg 13(3)(f) (representation by a vehicle-hire firm). TfL states that liability transfers only where the agreement fully meets s.66, the vehicle is on hire for a period of less than 6 months, there is a signed statement of liability, and the agreement carries the Schedule 2 information. Scheme: Greater London Low Emission Zone Charging Order 2006, as varied (ULEZ).

How to identify this in your case

For a vehicle-hire firm with a London ULEZ penalty. Check each point: you were the registered keeper and hire vehicles out as a business; the vehicle was out on hire at the time of the contravention; the original fixed hire period was less than six months (an extension you agreed does not change that test), and it was not hire-purchase; the person hiring it signed a statement of liability covering charges and penalty charges under a charging scheme during the hire; and the agreement contains every particular in Schedule 2 of the Road Traffic (Owner Liability) Regulations 2000 that applies to it — among them the full name, date of birth, address and driving licence details of the person who signed the statement of liability, the vehicle's registration mark and make and model, and the dates and times of the hire. Check the full list in Schedule 2 itself; if any particular that applies is missing, do not use this ground.

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.

To: Transport for London Re: Penalty charge notice [PCN_NUMBER] — vehicle [VEHICLE_REG] — contravention on [DATE] At the time of the contravention the vehicle was hired from us under a written hiring agreement to [hirer's full name and address], for an original fixed period of less than six months from [hire start date and time] to [expected end date and time], and the person hiring it had signed a statement of liability acknowledging liability for any charges or penalty charges incurred under a charging scheme during the currency of the hiring agreement. The agreement contains each of the particulars required by Schedule 2 to the Road Traffic (Owner Liability) Regulations 2000 that apply to it. The penalty charge is therefore payable by the hirer (Road User Charging (Charges and Penalty Charges) (London) Regulations 2001, reg 6(6)). We make representations on that ground (Road User Charging (Enforcement and Adjudication) (London) Regulations 2001, reg 13(3)(f)) and enclose copies of the hiring agreement and the signed statement of liability. Signed: [name], [position in the company], for and on behalf of [hire firm name] Date: [date]

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ULEZ charge — hired vehicle, wrong person billed

Legal basis

How to identify this in your case

Sample appeal wording

Beat It writes this argument automatically

Sources

Related appeal grounds

Next steps