PCN on a Hire or Courtesy Car: Are You Liable?

What a Notice to Hirer actually is

A Notice to Hirer is the letter a private parking company sends to you, the person who had the car, after the hire firm, leasing company or dealer that owns it has named you and handed over your paperwork. It exists because the registered keeper of a hire, lease or courtesy car is the company, not you, so the parking firm can't reach you directly. Schedule 4 of the Protection of Freedoms Act 2012 (usually shortened to POFA) is the only statutory route it has to you, and that route comes with hard deadlines.

That matters because the deadlines are often missed. If the chain below breaks at any point, the statutory right to recover the charge from you as hirer never arises at all. This guide walks through the chain, the day-counts, and the specific catch that applies to a dealer's free courtesy car. That is a different situation from a rental, and often a weaker one for the parking company.

First, be clear about one thing. This is about private parking charges, the ones issued by companies on supermarket car parks, retail parks and private forecourts. Council tickets work under a completely different law, covered further down. Schedule 4 also only extends to England and Wales; Scotland and Northern Ireland have their own arrangements, and this keeper and hirer liability mechanism isn't part of them.

How a parking charge on a hire car reaches you

Four things have to happen, in order, for a private parking operator to have a statutory right to your money. Miss one and the chain breaks.

Step 1 — the Notice to Keeper goes to the hire, lease or dealer company

DVLA records show a registered keeper, not a legal owner, and the two aren't always the same person. Gov.uk guidance puts it plainly: the registered keeper is the person who keeps the vehicle on the road and is responsible for taxing and registering it, which is "not necessarily the owner". The guidance gives leasing and hire as the cases where the two come apart, because the vehicle stays the property of the lessor or hire firm throughout.

On a hire, lease or dealer courtesy car, the company is the one named on the V5C logbook. So the parking operator's first letter, the Notice to Keeper, goes to them, not you.

The operator has its own deadline here. Where no ticket was put on the windscreen at the time, paragraph 9(5) of Schedule 4 gives it 14 days, beginning the day after the parking ended, to get the Notice to Keeper delivered. Where a windscreen ticket was issued, paragraph 8(5) sets a later window instead: the notice must arrive in the 28 days that follow the first 28 days after the windscreen ticket was given.

Step 2 — the company has 28 days to name you, with three documents

This is where hire vehicles diverge from ordinary cars. Under paragraph 13(2), the hire firm stops being on the hook only if it supplies the parking operator with three documents. It has 28 days to do that, starting the day after the Notice to Keeper was given. All three are needed:

• a signed statement that the vehicle was hired to a named person under a hire agreement at the material time
• a copy of the hire agreement itself
• a copy of a statement of liability signed by the hirer

That third document is the one that decides most of these cases. Paragraph 13(3) says it has to contain the hirer's own acknowledgement of responsibility for parking charges incurred while the car is hired to them, plus an address at which documents can be served on them. No signed statement of liability, no transfer.

Step 3 — the operator then has 21 days to send you the Notice to Hirer

Once those documents land, the clock restarts. Paragraph 14(3) gives the operator a 21-day window, beginning the day after the paragraph 13(2) documents were given to it, to serve you the Notice to Hirer. The notice can't arrive on its own, either. The hire paperwork and the original Notice to Keeper have to come with it.

Step 4 — what the Notice to Hirer must actually say

Paragraph 14(5) prescribes the contents. A compliant notice has to do six things:

• tell you the unpaid charges may be recovered from you
• refer you to the information in the Notice to Keeper
• warn you that after a further 21 days the operator can recover whatever remains unpaid
• set out any prompt-payment discount and the dispute or complaint arrangements available
• identify the creditor, and say how and to whom to pay
• state the date it was sent or given

Are you actually liable?

If every step above happened on time and the paperwork exists, then yes. The statutory route to you is open, and after the 21 days the notice warns you about, the operator can pursue you for the unpaid charge.

If a step was missed, the picture changes. Paragraph 14(1) only lets the creditor recover from the hirer where it is unable to recover from the keeper because of paragraph 13(2). The paragraph 14(2) conditions have to be met as well, including a compliant, in-time Notice to Hirer. Take away a condition and the statutory right against you doesn't arise.

Be careful about what that does and doesn't mean. A broken chain doesn't mean nobody is liable. It usually means liability stays with the registered keeper, the hire or lease company, under paragraph 4.

Many hire contracts allow that company to pass the cost on to you commercially, separately from POFA and often with an admin fee attached. It also doesn't stop an operator pursuing a driver it has identified by some other means.

So "the parking firm got its dates wrong" is a strong point against a Notice to Hirer specifically. It is not a guarantee that the money stops there. Whether it succeeds in any individual case is for an appeals service or a court to decide. If there's real money or a court claim involved, it's worth getting free advice from Citizens Advice rather than relying on a guide.

Two smaller points are worth knowing.

The first is that the industry sets limits of its own on top of the statute. The private parking sector Single Code of Practice is Version 1.1, jointly published by the British Parking Association and the International Parking Community, and in force since 17 February 2025. It caps a parking charge at £100, requires a discount of at least 40% for payment within 14 days of the notice, and requires operators to allow 28 days to appeal. Those are the trade bodies' own rules rather than statute.

The second is that the same Code confirms the basic principle underneath all of this: it is the driver who is liable for a parking charge, with keeper and hirer liability being a statutory fallback used when the driver isn't known.

The courtesy-car catch: did you sign anything?

A dealership courtesy car, the free runaround you're handed while yours is in for warranty work or a repair, is where this most often falls apart for the parking operator. There are two reasons.

The first is the signed statement of liability. When you collect a rental car, you sign a hire agreement that almost always includes exactly the acknowledgement paragraph 13(2)(c) requires. When a service department hands you a key and asks you to bring the car back with the same amount of fuel, you often sign nothing like that. If that document doesn't exist, the dealer can't satisfy paragraph 13(2), and the operator's paragraph 14 route to you never opens.

The second is more fundamental. Paragraph 13 applies where the vehicle "was at the time of parking hired to any person under a hire agreement with a vehicle-hire firm". Paragraph 13(6)(c) defines a vehicle-hire firm as "any person engaged in the hiring of vehicles in the course of a business". A franchised dealer lending a car free of charge as part of a repair is not obviously doing that.

If paragraph 13 doesn't apply at all, the operator is left pursuing the dealer as registered keeper, with no statutory route to the driver.

Be clear about the status of that argument, though. It's a reading of the statutory wording, not a settled point, and we've found no published appeals-service or court decision that pins it down either way. It's a case you'd have to put and win, not a rule you can rely on.

Now for what the statute doesn't say, because plenty of pages get this wrong. There is no minimum hire period. Paragraph 13(6)(a) defines a hire agreement as one letting a vehicle to a person "for a period of any duration", excluding only hire-purchase agreements under the Consumer Credit Act 1974. If you see a claim that this only applies to hires of six months or more, it isn't in the Act.

None of this is a magic escape. The dealer may still have a contractual term buried in the courtesy-car paperwork you did sign, and dealers do recharge these. But it does mean the specific document in front of you, a Notice to Hirer, may be built on a foundation that isn't there.

While we're on the subject of driving someone else's car, you're the one at the wheel. So spend thirty seconds checking that the car you've been handed is actually taxed and has a valid MOT before you drive it away. Our free car check shows both from the number plate alone.

This doesn't apply to council parking tickets

The initials are the same and the rules are not. A private Parking Charge Notice is a claim for breach of contract, governed by POFA as above. A council Penalty Charge Notice is a statutory penalty issued under the Traffic Management Act 2004 and its regulations, and it follows a completely separate process. The council serves a Notice to Owner, you make formal representations to the council, and if they're rejected you appeal to an independent adjudicator rather than to POPLA or the IAS.

There is a hire-vehicle provision in that regime too, but it's a different one. Regulation 5(4)(d) of the Civil Enforcement of Road Traffic Contraventions (Representations and Appeals) (England) Regulations 2022 gives a vehicle-hire firm its own ground for representations. It applies where the vehicle was hired from that firm under a hiring agreement and the person hiring it had signed a statement of liability acknowledging liability for penalty charge notices.

Regulation 5(7) then applies where the firm relies on that ground. It requires the firm to give the name and address of the person the vehicle was hired to. (These 2022 regulations replaced the 2007 ones that older guides still cite.)

The signed-statement requirement, in other words, runs through both regimes. The deadlines and the appeal routes do not transfer between them.

If your letter cites the Traffic Management Act, names a council, or offers you a discount for paying within 14 days of a Penalty Charge Notice, nothing on this page's day-counts applies to it.

What to do if you get a Notice to Hirer

Work through it in this order.

Confirm which kind of notice it is. Private parking company or council? If it's a council PCN, stop here and follow the council's own representations process.

Line up the dates. The notice must state the date it was sent or given. Compare that with the date the paragraph 13(2) documents were passed to the operator, since the notice should come with copies of them, and with the Notice to Keeper date. You're checking two things: did the hire firm respond inside its 28 days, and did the operator serve you inside its 21?

Check the notice's contents against paragraph 14(5). All six items listed earlier have to be there. A notice missing the creditor's identity, the dispute arrangements, or the date it was sent isn't a compliant notice.

Ask the dealer or hire firm what they sent. You're entitled to know what document they produced as your signed statement of liability. If they can't produce one, which is common with courtesy cars, say so in writing.

Appeal within 28 days. The Single Code requires operators to allow 28 days to appeal, and to suspend enforcement or debt recovery while an appeal to the relevant appeals service is live. If the operator rejects your appeal, the onward route depends on which trade body it belongs to: POPLA for British Parking Association members, the Independent Appeals Service for International Parking Community members. Both are free to motorists, and the notice itself should tell you which one applies.

For the wider picture on what a car actually costs to run and the paperwork that comes with it, see our guide to running a used car.

Common questions