Compliance
PCN management for a self-employed workforce: who pays, and how to run it
How UK operators handle penalty charge notices when self-employed drivers use the vans: who is liable, the deadlines, the transfer route and what to record.
25 April 2024 ยท Zerity editorial team
Short answer. A penalty charge notice goes to the vehicle's owner, and the owner pays unless a recognised transfer applies, such as a vehicle-hire firm naming a hirer who signed a statement of liability. Log each notice the day it arrives, match it to who had the vehicle, then pay, challenge or transfer before the dates printed on it.
Operational guidance, not legal advice. It follows the regulations for England; Wales, Scotland and Northern Ireland have their own rules, and London bus-lane and moving-traffic PCNs follow separate London legislation. Couriers are one example; field-service, cleaning and facilities teams with vans face the same notices. Checked against GOV.UK and legislation.gov.uk on 20 October 2026.
- Which notice are you holding?
- Who is liable when a self-employed driver gets a PCN?
- What are the deadlines?
- How should an operator run PCNs from intake to close?
- What should you agree with self-employed drivers up front?
- What should go on the file?
- Where do operators usually slip up?
- How Zerity helps
- Common questions
- Sources
Which notice are you holding?
Different notices come from different issuers and run on different clocks, so sort them first.
| Notice | Who issues it | What it is | How to handle it |
|---|---|---|---|
| Penalty charge notice (PCN) | A council, Transport for London or Dart Charge | A civil charge for parking, some traffic rules such as bus lanes, or an unpaid congestion, low emission zone or Dart Charge | This guide |
| Fixed penalty notice (FPN) | The police, a council or the DVSA | Criminal enforcement; some parking FPNs carry penalty points | A separate record from PCNs |
| Private parking charge | A landowner or parking company | A charge for parking on private land, such as a supermarket car park | Its own appeal route; check the ticket |
| DVS penalty | Transport for London | A London scheme for heavy goods vehicles, covered separately | See our DVS compliance guide |
GOV.UK's guide to paying a ticket sets out these types and says how you pay depends on what the notice is and who issued it.
Who is liable when a self-employed driver gets a PCN?
Under regulation 6 of the 2022 General Regulations, a penalty charge is payable by the person who was the owner (normally the registered keeper) of the vehicle at the time, unless the hire route below applies. These regulations cover council parking PCNs and, outside London, bus-lane and moving-traffic PCNs. Dart Charge, congestion, low emission zone and London bus-lane and moving-traffic PCNs have their own rules. Fixed penalties and private parking charges are not PCNs.
For a self-employed workforce that means:
- The person uses their own vehicle. The notice normally goes to them as owner. If one reaches you, pass it on and note it.
- The vehicle is yours. The notice comes to you. You pay it unless a recognised ground applies.
One ground is the vehicle-hire route. Regulation 5(4)(d) of the Representations and Appeals Regulations lets a vehicle-hire firm make representations where the vehicle was hired under a hiring agreement and the hirer had signed a statement of liability for penalty charges during the hire. The representations must give the hirer's name and address. If the authority accepts them, regulation 6(2) of the 2022 General Regulations makes the charge payable by the hirer. London bus-lane and moving-traffic PCNs run under the London Local Authorities and Transport for London Act 2003, not SI 2022/576.
Section 66 of the Road Traffic Offenders Act 1988 supplies the definitions: a "vehicle-hire firm" is any person engaged in hiring vehicles in the course of a business, and a "hiring agreement" must contain prescribed particulars and excludes hire-purchase. For police and DVSA fixed penalties, the same section sets a hired-vehicle route for agreements with a fixed period of less than six months. Private parking charges follow Schedule 4 to the Protection of Freedoms Act 2012, where a vehicle-hire firm can stop the creditor pursuing it by sending a signed hire-firm statement, a copy of the hire agreement and the hirer's signed statement of liability within 28 days of the notice to keeper. The creditor then has 21 days to send a notice to hirer.
Whether your van arrangement counts as a hiring agreement is a question for your adviser, and how you word vehicle terms can bear on the wider relationship. Employment status is fact-specific; read GOV.UK's employment status guidance and use HMRC's Check Employment Status for Tax (CEST) tool where it fits.
What are the deadlines?
Take every date from the notice itself. GOV.UK says you usually have 28 days to pay, and the charge is usually halved if paid within 14 days (21 for postal camera PCNs). An unpaid windscreen PCN brings a notice to owner after 28 days; a charge certificate can follow 28 days later and you have 14 days to pay the original charge plus 50%; after that comes a court order.
For a postal PCN, the PCN itself is the enforcement notice. You can make representations within 28 days beginning with the date it is served (later ones may be disregarded, regulation 3(2)); do not wait for a notice to owner.
For a windscreen PCN, if it remains unpaid, the authority may serve a notice to owner after 28 days. The notice to owner must tell you that representations made more than 28 days after it was served may be disregarded (regulation 3(2)). The authority then has 56 days to decide; if it misses that window, it is treated as having accepted your representations (regulation 6).
Record five dates on each notice: the contravention, service, the end of any discount, the last day for representations, and when a charge certificate would follow.
How should an operator run PCNs from intake to close?
- One intake point. Route every notice, from every site, to one named person.
- Log it the same day. Notice number, issuer, vehicle registration, date, time, place, the five dates and a scan of the notice.
- Match it to who had the vehicle. Use your vehicle handover and work records for that day. If you cannot show who had the van, you cannot transfer or recharge anything.
- Tell the person. Send them the notice and evidence, and give them a short window to respond, for example with a photo of a loading bay or a delivery note.
- Decide. Pay within any discount period, make representations, or use the hire route if your adviser has confirmed it applies. Record who decided and why.
- Settle any recharge. Only where your written agreement with that person allows it, and only after they have seen the notice. Our vehicle damage guide covers the same question for repairs.
- Close and review. Record the outcome and the date. Each month, look for patterns by site, street and time.
What should you agree with self-employed drivers up front?
Put vehicle terms in writing before the first shift:
- who pays a notice issued while they had the vehicle, and how you will tell them;
- how quickly you will pass a notice on, and how they can send evidence;
- whether any recharge can be made and how it is shown to them;
- where the hire route is used, the hiring agreement and signed statement of liability, kept where you can produce them.
Ask each person to confirm they have read the vehicle terms, and keep that confirmation on file. When the engagement ends, settle open notices as part of the exit; see offboarding self-employed workers.
What should go on the file?
Keep the scan, five dates, evidence, decision, any recharge and outcome with the vehicle and the person, not in a shared inbox. Our record-keeping guide shows how notices fit into the wider audit file, and fleet compliance covers the rest of the vehicle side.
Where do operators usually slip up?
- Notices sit in the post. The discount period passes before anyone opens the envelope.
- A London date applied everywhere. Read each notice.
- Private charges paid as if they were PCNs. They are a different route.
- Recharges without a written basis. Agree the terms first.
A new Private Parking Code of Practice was laid in Parliament on 20 October 2026; it is not yet in force.
How Zerity helps
Zerity is one operating system for compliance and operations across your self-employed workforce. On the vehicle and people side:
- A vehicle and equipment register holds MOT, tax and insurance expiry, with an optional QR label. See asset management.
- The rota is published to the driver app, and days worked feed the self-bill. See scheduling.
- Drivers complete walkaround checks on their phone before every shift. See vehicle inspection software.
- Contracts, policies and handbooks are stored with version control, and you can see who has read and signed what.
- Drivers are tagged by depot and network, and one account covers every site you run. See depots and the multi-depot guide.
- Every licence and policy expiry date is tracked in one place.
- A penalty charge notice can be logged against the vehicle and the driver, with its deadline and outcome.
Zerity is not GPS telematics, not dispatch, and not a workshop system. Deciding whether to pay, challenge or transfer a notice stays with you, and Zerity does not decide anyone's employment status. Zerity is free for operators.
Book a demo to see vehicles, people and records for every site in one place.
Common questions
Who pays a PCN when a self-employed driver was driving?
The vehicle's owner (normally the registered keeper) at the time, unless a recognised ground applies. If the person uses their own vehicle, that is them. If the vehicle is yours, it is you, unless for example the vehicle-hire route applies and the authority accepts it.
Can I transfer a PCN to the driver?
A vehicle-hire firm can make representations where the vehicle was hired under a hiring agreement and the hirer signed a statement of liability, giving the hirer's name and address. If the authority accepts, the hirer pays. Whether your arrangement qualifies is a question for your adviser.
How long do I have to pay or challenge a PCN?
Usually 28 days to pay, and the charge is usually halved if paid within 14 days (21 for postal camera PCNs). Late representations may be disregarded. Use the dates printed on the notice.
Is a private parking charge the same as a PCN?
No. A PCN comes from a council, Transport for London or Dart Charge. A private parking charge comes from a landowner or parking company and has its own appeal route, with separate rules for passing a charge to a hirer.
Can I recharge a PCN to a self-employed driver?
Only where your written agreement with that person allows it, after showing them the notice and hearing their response. Take advice on the wording.
Sources
- Paying a ticket (GOV.UK)
- Civil Enforcement General Provisions (England) Regulations 2022, regulation 6
- Civil Enforcement Representations and Appeals (England) Regulations 2022: regulation 3; regulation 5; regulation 6
- Road Traffic Offenders Act 1988, section 66
- Protection of Freedoms Act 2012, Schedule 4: paragraph 13; paragraph 14
- Traffic Management Act 2004, section 92
- DfT guidance for local authorities on enforcing parking restrictions
- Private Parking Code of Practice laid, 20 October 2026 (GOV.UK news)
- Employment status (GOV.UK)
- Check employment status for tax (GOV.UK)