London council PCN on a hire vehicle: passing it to the hirer

General information for England, not legal advice. Rules differ in Scotland, Wales and Northern Ireland, and every notice is different. Always check the notice and the issuer's own guidance. Last reviewed 13 November 2026.

Three kinds of council PCN

• Parking. The hire-firm ground applies.
• Moving traffic. In London these come under the London Local Authorities and Transport for London Act 2003, which also has a hire-firm ground.
• Bus lanes. London bus lanes come under the London Local Authorities Act 1996, which has no hire-firm ground. On a hire of less than six months, the hire company pays.

Wait for the right notice

The hirer only becomes liable after a notice to owner (the letter the council sends the registered keeper) and an accepted representation. Camden and Newham say to wait for the notice to owner, the enforcement notice, or a PCN sent by post from a camera. A windscreen ticket is too early.

What the council needs

• A copy of the hire agreement covering the date and time, for a fixed period of less than six months. Extensions are allowed.
• Every Schedule 2 particular in the agreement. Schedule 2 of the Road Traffic (Owner Liability) Regulations 2000 lists what must be recorded, including the hirer's date of birth and licence details and the vehicle's make and model.
• A statement of liability signed by the hirer, accepting liability for any PCN during the hire.
• The hirer's name and address. Westminster also asks for the hirer's permanent address, date of birth and licence number, which aren't needed for a company hirer.
• A statement from you that the vehicle was on hire to the named hirer, signed by or for the company.

Some boroughs add their own rules. Greenwich asks for an agreement that is BVRLA compliant and on headed paper. Havering wants a liability clause in the agreement and rejects courtesy car agreements without one. Hackney asks for a copy of the agreement signed by the hirer.

Time limits

You have 28 days from service of the notice to owner or enforcement notice. After that the council may ignore your representation. A council has 56 days to decide on a parking representation, or it is treated as accepted.

Common reasons councils reject a transfer

• A hire of six months or more. Westminster, Camden and Newham want the lease agreement instead, on the "not the owner" ground.
• A missing particular. In one London tribunal case a missing vehicle model was enough.
• An unsigned statement of liability, or no liability clause.
• Filing on a windscreen ticket before the notice to owner.
• Files too large. Some council websites take only 2 MB per file, and a phone scan of a long agreement is often bigger.
• A London bus lane PCN on a short hire.

How PCN Flow handles council PCNs

You upload the notice. PCN Flow reads it with AI, finds the hire agreement covering the date and time, and checks the signed agreement, the liability clause or statement, the hirer's name and address, and that the vehicle and date fall inside the hire. It stops a council PCN on a hire of six months or more for your team to decide, for example as Fine Not Assignable. When you press Make Representation, it files on the issuer's website where it can, otherwise by email. Nothing goes by post. Then it tells the hirer in your company's name.

For TfL red routes, see TfL PCNs on hire vehicles. For every issuer, read transfer of liability, explained.