Hire companies: transferring PCN liability to the hirer

When a hired vehicle gets a council PCN, the Notice to Owner (or postal PCN) goes to the registered keeper, which is you. The law lets a vehicle-hire firm pass liability to the hirer, but only if the paperwork meets strict requirements. Adjudicators regularly reject transfers because the hire agreement is missing prescribed details.

1. Does your business qualify?

Vehicle-hire firm means "any person engaged in hiring vehicles in the course of a business" (Road Traffic Offenders Act 1988, s.66(8), applied by SI 2022/576 reg 5(8)).
The hiring agreement must let the vehicle for a fixed period of less than six months. It still counts if it can be extended, and the hire continues while the hirer keeps the vehicle with your consent after the fixed period (s.66(7)).
It must contain the prescribed particulars (Schedule 2 to the Road Traffic (Owner Liability) Regulations 2000, listed below). Hire-purchase agreements are excluded.
Long-term leases or contract hire of six months or more fall outside this route. Whether a leasing company can instead argue it wasn't the "owner" (the person by whom the vehicle is kept, TMA 2004 s.92) depends on the facts. Treat that as uncertain and get advice.

2. Which PCNs can be transferred?

PCN type	Hire-firm ground?	Law
Parking, anywhere in England including London	Yes	SI 2022/576 reg 5(4)(d) and 5(7); SI 2022/71 reg 6(2)-(3)
Bus lane and moving traffic outside London	Yes	Same 2022 regulations
Moving traffic in London (boxes, banned turns, 52M etc.)	Yes (qualifying agreement under 6 months plus signed statement of liability)	London Local Authorities and Transport for London Act 2003
Bus lanes in London	No. There is no statutory hire ground. The keeper stays liable and must recover the cost from the hirer under the contract.	London Local Authorities Act 1996 (see TfL FOI-1665-2425; London Tribunals bus lane grounds)
Congestion Charge, ULEZ/LEZ, Dart Charge, clean air zones	These run under separate road-user-charging rules, which this guide doesn't cover. Check the notice.	-

3. The documents you need

A copy of the hiring agreement covering the date and time of the contravention.
A copy of the statement of liability signed by the hirer, accepting liability for any PCN during the hire. Form H in Schedule 1 to the 2000 Regulations is the model wording, and many firms build it into the rental agreement.
Your representation, made within the time limit, relying on the hire-firm ground and stating the hirer's name and address. This is mandatory under reg 5(7).

Particulars the hiring agreement must contain (Schedule 2, 2000 Regulations)

About the person signing the statement of liability	About the hire
Full name Date of birth Permanent address Address at time of hiring (if different and the stay is likely to be more than two months from the date of hiring) Driving licence: country of issue (if not UK), serial or driver number, and expiry date, which should be no earlier than the expected end of the hire	Registration mark, make and model of the vehicle Registration, make and model of any substitute vehicle, and the time and date of the change Time and date the original hire started Expected time and date the original hire ends Time and date of any authorised extension, and its expected end Actual time and date of return (or, if returned out of hours, when you next opened). Only your copy needs this.

About the person signing the statement of liability

About the hire

Full name
Date of birth
Permanent address
Address at time of hiring (if different and the stay is likely to be more than two months from the date of hiring)
Driving licence: country of issue (if not UK), serial or driver number, and expiry date, which should be no earlier than the expected end of the hire

Registration mark, make and model of the vehicle
Registration, make and model of any substitute vehicle, and the time and date of the change
Time and date the original hire started
Expected time and date the original hire ends
Time and date of any authorised extension, and its expected end
Actual time and date of return (or, if returned out of hours, when you next opened). Only your copy needs this.

Agreements commonly fail when they're not on headed paper or don't name the hire company, miss the hire period times, or leave out the hirer's driving licence details. All three came up in a 2026 adjudicator decision published on the key cases site. Build every field into your template and make it mandatory.

4. Timescales

Event	What to do / time limit
Windscreen PCN while on hire	There's no formal transfer at this stage. You can tell the council the vehicle was on hire (informal challenge), but the formal transfer happens on the Notice to Owner.
Notice to Owner or postal (camera) PCN arrives	Make representations on the hire ground within 28 days of service. Late ones may be disregarded.
Council's decision (TMA PCNs)	Must be served within 56 days of receiving your representations, or they're deemed accepted.
Accepted	Your notice is cancelled. The hirer is treated as the owner, and the council can serve a new notice on them (SI 2022/71 reg 6(2)-(3); SI 2022/576 reg 6(8)).
Rejected	Appeal to London Tribunals or the Traffic Penalty Tribunal within 28 days of the Notice of Rejection.

5. Making the representation

Many councils and TfL have a hire/lease transfer option on their online challenge form or a dedicated email address. Check the NtO. Your representation should include the PCN number, registration, contravention date and time, the hirer's full name and address, the hire start and end, and the two documents.

Generate a transfer-of-liability letter with the statutory wording and a document checklist.

Hire company letter

6. Good practice for hire firms

Use one agreement template with every Schedule 2 field and the statement of liability built in, signed (or e-signed) at collection.
Record exact collection and return times. Contraventions just outside the hire window are a common dispute.
Check the licence expiry is no earlier than the expected return date.
Keep a PCN log: date received, 28-day deadline, date submitted, outcome.
Keep the original agreement and signed statement for at least as long as any PCN could be pursued.
For London bus lane PCNs (no transfer route), check your rental terms allow you to recharge the hirer, and pay within the discount period if you're not disputing it.
Any recharge or admin fee in your terms must be transparent and fair to consumers. Take advice on your terms and conditions.

Frequently asked questions

Can a car hire company transfer a PCN to the driver?

Yes, for most council PCNs in England. The firm makes representations against the Notice to Owner on the vehicle-hire-firm ground, giving the hirer's name and address, with a copy of a qualifying hiring agreement (fixed period under six months, containing the prescribed particulars) and the hirer's signed statement of liability. London bus lane PCNs are the main exception.

What must a hire agreement contain to transfer a PCN?

The particulars in Schedule 2 to the Road Traffic (Owner Liability) Regulations 2000. These include the hirer's full name, date of birth, address and driving licence details, the vehicle's registration, make and model, and the start, expected end and actual return times of the hire.

Can liability be transferred for a London bus lane PCN?

No. London bus lane PCNs are issued under the London Local Authorities Act 1996, which has no hire-firm ground. The registered keeper remains liable.

Official sources

More guides

Informal challenge: the first step Notice to Owner and formal representations Got a Notice of Rejection?Appealing to the tribunal Charge Certificate and Order for Recovery Order for Recovery: witness statement (TE13 / TE9)Fines and discounts Private parking tickets

Not legal advice. This site gives general information about council PCNs in England, based on official sources (last reviewed 21 October 2026). Rules and amounts change and every case is different. Always check the notice you received, your council's website and the official sources, and consider independent advice for complex cases. PCN Codes is not connected to any council, TfL, London Tribunals or the Traffic Penalty Tribunal.