How to Challenge a Code 67 PCN for No HGV Safety Permit

What a Code 67 PCN Alleges

TfL's Direct Vision Standard and HGV Safety Permit Scheme applies to lorries over 12 tonnes gross vehicle weight entering or operating within the scheme area. Code 67 concerns having no valid permit. A suitable star rating or fitted safety equipment does not by itself establish that a permit was granted. LLCS permission and LEZ compliance are separate matters.

Challenge the HGV Safety Permit PCN Directly

Make formal representations to TfL against the postal HGV Safety Permit PCN. Do not wait for a parking Notice to Owner. Use the person or organisation named on the notice and include written authority if someone else submits it.

• Read the allegation: code 67 concerns no valid permit; code 68 concerns permit conditions. Attach the evidence that addresses that allegation.
• Submit the representation through TfL's official PCN challenge service or the postal address on the notice. A permit-service complaint is not a PCN representation.
• TfL may request further evidence, accept the representation or issue a Notice of Rejection. Answer any evidence request within the time given.
• After formal rejection, appeal to London Tribunals using the verification details supplied. This is not a Traffic Penalty Tribunal case.

Permit approval, equipment compliance, operator identity and mitigation are separate issues. Explain which one answers the notice rather than supplying a general fleet-compliance statement.

TfL HGV Safety Permit PCN Deadlines and Amounts

TfL's published DVS challenge guidance gives 28 days from service for representations and a 14-day discounted payment period from service. It states a £550 penalty, reduced to £275 within that discount period. Check the notice and the guidance applying on its date.

• TfL says a received representation freezes the PCN while it is investigated; retain confirmation that the formal representation was received.
• Respond to a request for further evidence within TfL's stated period. A permit application or complaint does not replace this response.
• A Notice of Rejection gives the London Tribunals appeal instructions and deadline. Submit within the stated 28-day period and keep evidence of the notice's date and receipt.

Do not use London borough parking bands or assume a statutory 56-day parking-representation rule applies to this scheme. If no payment or representation is made in time, TfL explains that the Charge Certificate increases the £550 penalty to £825.

The Permit Approval, Vehicle Identity and Exemption Record

• TfL permit approval, status history and correspondence showing the dates relevant to the PCN.
• Registration, VIN, weight plate and any documented personalised-registration change.
• The camera evidence and location, compared with fleet records and the scheme boundary.
• Manufacturer or conversion records supporting a claimed full exemption or vehicle classification.
• The application and equipment records, with a clear distinction between submitted, approved and subsequently changed information.

An installation invoice is evidence of equipment, not proof that TfL granted a permit. Applying after the PCN can prevent future problems but does not automatically make the earlier journey compliant.

Was the Correct Vehicle Covered by an Active Safety Permit?

• A valid permit existed at the time: provide the approval reference and effective dates for the exact registration. Check whether the record was expired, suspended or revoked rather than assuming a previous application still covered the journey.
• The vehicle was misidentified or outside the scope: match the camera image, registration, vehicle specification, weight and location. A fleet vehicle with a similar plate is not the same vehicle.
• A full exemption applied: identify the exemption in TfL's current operator guidance and prove the vehicle's construction or use. A partial equipment exemption does not necessarily remove the obligation to obtain a permit.
• A registration or administrative error affected the record: provide TfL correspondence, the VIN, plate-transfer documents and application history. Distinguish an already approved permit recorded incorrectly from an application never completed.
• The PCN names the wrong operator: provide the operator-licence or other relevant records. Naming the driver does not answer TfL's operator-liability ground.

Vehicles rated zero, one or two stars need the applicable Progressive Safe System and permit; an old Safe System approval should not be assumed current. TfL also states that permits are not transferable to another vehicle or registration. Check the grant and conditions that applied on the contravention date.

What to Include in a Code 67 Representation

Identify the permit or exemption that covered the vehicle at the material time, or explain the proven administrative error. Include the exact registration, VIN where relevant and approval timeline. If there was no valid permit, present any exceptional circumstances honestly as mitigation rather than asserting that fitted equipment was itself a permit.

TfL's Online and Postal DVS Representation Details

The official TfL challenge page links to the online PCN service. It also lists: Direct Vision Standard and HGV Safety Permit, PO Box 335, Darlington, DL1 9PU. Check that address against the current notice before posting, and retain proof of submission.

Give the PCN number, registration, permit reference and the role or authorisation of the person submitting. A representation about operator identity needs the relevant operator information, not merely a different driver's name.

After TfL Rejects an HGV Safety Permit Representation

Use the Notice of Rejection to appeal to London Tribunals and submit the permit, technical and inspection evidence relevant to the disputed ground. Check TfL's evidence pack and answer any inaccurate vehicle details or findings.

If allowed, the penalty is cancelled. If refused, follow the adjudicator's payment instructions. A later Order for Recovery concerns debt registration and specific procedural remedies; it is not a fresh opportunity to dispute the equipment allegation. Permit suspension or revocation may also need separate attention.