How to Challenge a Code 68 PCN for HGV Safety Permit Conditions

What a Code 68 PCN Alleges

An active HGV Safety Permit does not remove the need to comply with its conditions. Code 68 alleges a breach of those conditions, rather than the absence of a permit alleged by code 67. TfL can also suspend or revoke a permit. The relevant evidence is the vehicle's actual equipment, configuration and operation at the time, assessed against the applicable permit and Progressive Safe System requirements.

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.

Inspection Findings and Progressive Safe System Records

• The permit grant and conditions, vehicle identity and the precise alleged non-compliance.
• Installation and commissioning certificates identifying the sensors, cameras or other components in dispute.
• Dated photographs, maintenance records and test results showing the relevant system's operation.
• Manufacturer type-approval documents or technical evidence for a permitted alternative or partial exemption.
• Fault reports and repair records separating the condition at the time from later remedial work.

Do not answer a conditions allegation only with a permit screenshot. Equally, a new installation after the PCN should not be presented as though it proves earlier compliance.

Match the Alleged Defect to the Actual Permit Condition

• The wrong condition or standard was applied: obtain the permit conditions and technical requirement relevant to the vehicle and date. Do not assess a current vehicle solely against superseded Safe System guidance.
• The required equipment was present and functioning: provide installation, commissioning and maintenance evidence that addresses the particular defect. A general statement that the vehicle passed an inspection does not answer a specific sensor or camera allegation.
• A permitted alternative or partial exemption applied: match manufacturer type-approval evidence or the specialist-vehicle provision to the precise component. An exemption from one component is not exemption from the whole scheme.
• The inspection evidence does not identify this vehicle or defect: compare the registration, configuration, photographs and test records. A cropped image may omit equipment but does not by itself prove its absence.
• A temporary failure or exceptional event requires consideration: show the fault report, discovery time and action taken. Rectification after the event may support mitigation but is not proof that the condition was met earlier.

Use TfL's operator guidance and the permit conditions to distinguish full exemptions from component-specific concessions. Foreign registration, left-hand drive or an abnormal load does not automatically exempt every safety requirement. A commercial deadline is not permission to operate in breach of the permit.

What to Include in a Code 68 Representation

Quote the condition alleged to have been breached and respond to each inspection finding with its matching record. Explain any permitted alternative or partial exemption precisely. Keep evidence of later repairs and requests for discretion separate from evidence that the vehicle complied at the material time.

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.