PCN transfer of liability explained for hire companies

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.

The two kinds of ticket

	Penalty Charge Notice	Parking Charge Notice
Issued by	Councils and TfL	Private parking operators
What it is	A civil penalty under statute	A charge under private land contract terms
Who it goes to	The owner (the registered keeper), usually through a Notice to Owner	The keeper, through a Notice to Keeper
How it moves to the hirer	A representation on the hire-firm ground	A statement to the operator, who then sends a Notice to Hirer

Council PCNs and the 14 and 28 day windows

A parking PCN is usually put on the windscreen or handed to the driver. If it isn't paid, the council sends a Notice to Owner to the registered keeper. A camera PCN comes straight to the keeper by post.

14 days: the usual discount period (21 for camera parking PCNs served by post). The notice says which. This is for payment, and it isn't your deadline to transfer.
28 days: the usual time to make representations, counted from service of the Notice to Owner or postal PCN.

Some councils won't take a transfer on a windscreen ticket until the Notice to Owner has been issued. Miss the 28 days and the council can issue a charge certificate, which raises the amount by half.

What the hire-firm ground needs

For most council and TfL PCNs, a hire firm can say the vehicle was on hire and name the hirer. The issuer will expect:

A hiring agreement for a fixed term of less than six months that covers the date and time
The prescribed particulars of the hire (the Road Traffic (Owner Liability) Regulations 2000, Schedule 2)
A statement of liability signed by the hirer, accepting liability for penalties during the hire and giving an address for documents
The hirer's name and address

A missing signature or a gap in the particulars is a common reason for rejection, and so is a fixed term of six months or more.

TfL and road charging

TfL issues PCNs for the congestion charge, ULEZ and red routes. TfL and Dart Charge look for the same kind of hire paperwork, so PCN Flow applies the six-month stop to them. Clean Air Zone charges elsewhere and Merseyflow don't have that limit in PCN Flow.

London bus lanes: the exception

London bus lane PCNs (contravention code 34) fall under legislation with no hire-firm ground. The keeper generally stays liable, so the usual answer is to pay and recharge the hirer. Bus gates under moving traffic powers (code 33) can usually be transferred.

Private parking charges

Under the Protection of Freedoms Act 2012, Schedule 4, an operator sends a Notice to Keeper. To pass it on, a hire firm gives the operator, within 28 days, a statement that the vehicle was on hire, a copy of the hire agreement and the hirer's signed statement of liability. The operator can then send a Notice to Hirer. Many operators also offer a 14-day reduced rate, and some have their own transfer websites.

Police notices are different

A Notice of Intended Prosecution or a section 172 request is a legal requirement to name the driver, usually within 28 days. It isn't a transfer of liability. PCN Flow doesn't file these and holds them back from Make Representation.

Telling the hirer

Issuers contact the hirer once they accept the transfer, but hirers can be slow to open post. Telling them yourself, with the PCN reference and what happens next, cuts disputes. Many hire companies also charge an admin fee, if their agreement allows it.

Guides by issuer

Doing this for every ticket

The work is the same each time, on a different website: find the hire, check the paperwork, type it in, attach the agreement, save the proof and tell the hirer. PCN Flow does that part.

Transfer of liability, explained