ULEZ, clean air zones and tolls: recovering the charge from your hirer

A hirer drives through central London, crosses the Dartford bridge and comes back through a clean air zone. None of it shows on the car, and every charge is billed to the registered keeper, which is you, often after the hire has ended. This guide sets out what each scheme charges, how and when it must be paid, what happens when it is not, and how to recover the cost from the hirer fairly. Every figure is linked to the authority or operator that sets it, and figures change, so check the source before you print a price list. It is general information, not legal advice. Where a point is not settled by the source, the guide says who to confirm it with.

1. Who gets billed: the keeper first

Each scheme finds the vehicle by its number plate and bills the registered keeper. TfL issues a Congestion Charge penalty to the registered keeper (TfL: Congestion Charge penalties and enforcement); Scottish councils send low emission zone penalties to the registered owner (mygov.scot: fines for low emission zones); the Tyne Tunnels operator asks DVLA for the keeper's name and address when a toll is unpaid (TT2: how an Unpaid Toll Charge Notice works).

That leaves you two ways to run a fleet. You can pay the charges yourself, through accounts that pay automatically, and recharge the hirer. Or you can leave payment to the hirer and, if they miss the deadline, transfer the penalty to them where the scheme allows it. The second needs a hire agreement built for it, covered in the car hire agreement, and a fast response to every notice, covered in PCNs and fines on hire cars.

2. London: ULEZ and the Congestion Charge

ULEZ

The Ultra Low Emission Zone operates 24 hours a day, every day except Christmas Day, across all London boroughs but not the M25. A vehicle that does not meet the standards and is not exempt pays £12.50 a day, which covers cars, motorcycles, vans and specialist vehicles up to and including 3.5 tonnes and minibuses up to 5 tonnes (TfL: Ultra Low Emission Zone). You can pay up to 90 days in advance or by midnight on the third day after the journey, and charging days run midnight to midnight (TfL: ULEZ payments), so a drive that crosses midnight can mean two charges. TfL lists motor caravans between 2.5 and 3.5 tonnes among the vehicles covered, and the penalty for a car, van or motor caravan in that range is £180, reduced to £90 if paid within 14 days (TfL: penalty charges for ULEZ).

For a hire fleet the ULEZ is mostly a buying decision. Petrol vans registered from January 2006 should meet the Euro 4 standard and diesel vans sold from September 2016 the Euro 6 standard, but TfL tells you to check each vehicle's registration rather than rely on age (TfL: ULEZ vans, minibuses and more). The start-up guide's vehicles section covers the car standards.

Congestion Charge

The Congestion Charge applies 07:00 to 18:00 Monday to Friday and 12:00 to 18:00 at weekends and on bank holidays, with no charge from Christmas Day to the New Year's Day bank holiday inclusive. It is £18 if paid in advance or on the day, or £21 by midnight on the third day after travel (TfL: paying the Congestion Charge). The previous 100% discount for electric vehicles has ended; electric cars now pay £13.50 and electric vans £9, but only when registered on Auto Pay (TfL: Congestion Charge changes). An unpaid charge brings a £180 penalty, £90 if paid within 14 days, rising to £270 once a charge certificate is issued (TfL: Congestion Charge penalties and enforcement).

Paying automatically

TfL runs Auto Pay for up to 5 vehicles and Fleet Auto Pay for businesses with 6 or more. Fleet Auto Pay bills monthly by Direct Debit for the Congestion Charge, the Blackwall and Silvertown tunnels charge, ULEZ and LEZ, takes up to 10 working days to set up, has no registration or renewal fees, and lists protection from penalty charge notices while registered among its benefits (TfL: Fleet Auto Pay). Remove vehicles you sell, or you keep paying for them.

3. Clean air zones in England

Outside London, clean air zones are run by councils. They operate 24 hours a day, every day, the charge period runs midnight to midnight, and the charge must be paid by 11:59pm on the sixth day after driving into the zone, or up to 6 days before (GOV.UK: driving in a clean air zone). Which of your vehicles pay depends on the zone's class:

The table follows GOV.UK's list of zones and classes, where class C covers vans and minibuses and class D adds cars (GOV.UK: driving in a clean air zone). The minimum standard for cars, vans and minibuses is Euro 6 for diesel and Euro 4 for petrol. Businesses with 2 or more UK-registered vehicles can open an account to check and pay for several vehicles and set up payment by bank account. The charge amounts and penalty amounts are set by each council and are not listed on the GOV.UK page; check them with the council or the online service, and the penalty on any notice you receive.

4. Scotland's low emission zones

Scotland's zones work differently: there is no daily charge to pay. Aberdeen, Dundee, Edinburgh and Glasgow have low emission zones in their city centres, operating 24 hours a day including Christmas Day, enforced by cameras and penalty charge notices, and you cannot prepay to avoid a fine (mygov.scot: low emission zones in Scotland). The standard is Euro 4 for petrol and Euro 6 for diesel cars and vans (mygov.scot: check if you can drive a vehicle in a LEZ).

The first penalty is £60, reduced to £30 if paid within 14 days. It doubles each time the same vehicle is driven in the same zone within 90 days, up to £480 for cars and light goods vehicles, and resets to £60 after 90 days without a penalty (mygov.scot: fines for low emission zones). Where the keeper is a vehicle hire firm and the vehicle was hired under an agreement containing the section 66 particulars, the penalty is payable by the hirer (Low Emission Zones (Emission Standards, Exemptions and Enforcement) (Scotland) Regulations 2021, regulation 5). The only real control is the fleet itself: a non-compliant vehicle sent to Glasgow for a week of commuting can collect a run of doubling penalties before the first notice arrives.

5. Dart Charge, M6 Toll and other crossings

Dartford Crossing

The Dart Charge applies from 6am to 10pm every day and must be paid by midnight the day after crossing. A car or motorhome is £3.50, or £2.80 with a pre-pay account; a two-axle van is £4.20, or £3.60 pre-pay. An unpaid charge brings a £70 penalty, reduced to £35 within 14 days and increased to £105 if unpaid (GOV.UK: pay the Dartford Crossing charge). A customer who crosses on Sunday and returns the car on Tuesday has already missed the deadline unless your account paid it.

M6 Toll

The M6 Toll is paid at toll plazas: you tap a card or device on the contactless reader to raise the barrier, the maximum toll for the journey is pre-authorised, and the final price is taken once you leave the road (M6toll: pricing). Account holders who register vehicle registrations can pass through using number plate recognition. A driver who cannot pay at the booth gets a payment notice and has 6 days from when the trip is validated to pay online, to avoid additional charges of at least £70 and then debt recovery (M6toll: payment notice). Since the toll is normally paid at the barrier, what can reach you is a payment notice when the hirer could not pay.

Mersey Gateway and Tyne Tunnels

Both are free-flow, with no booths. Mersey crossings must be paid in advance or by 11.59pm the day after the journey, or a penalty charge notice follows (merseyflow: toll charges). Tyne Tunnels tolls must be paid by midnight the day after; an unpaid toll brings a notice to the keeper of £30 plus the toll, rising to £60 and then £100 plus the toll if it stays unpaid (TT2: Unpaid Toll Charge Notices). Whether these operators accept a transfer to the hirer, and on what documents, is for you to confirm with each operator.

6. Recovering the charge from the hirer, fairly

For consumer hires, the terms that recover these costs are judged for fairness like any other. A term requiring a consumer in breach to pay a disproportionately high sum in compensation may be unfair (Consumer Rights Act 2015, Schedule 2, paragraph 6). The CMA says an administration fee charged during a contract with no service provided in exchange is unlikely to be protected as part of the price (CMA37, paragraph 5.10), and that sanctions are more likely to be fair when the sum is objectively proportionate, clear and upfront, and easy to avoid (CMA37, paragraph 6.65). Terms built on that pattern:

1. say which charges you pay through your accounts and which the hirer must pay themselves, with the deadlines;
2. recharge a charge you paid at the exact amount, itemised with the date and scheme;
3. state any handling fee in pounds, at a level that reflects the real cost of processing it, and do not add it when the hirer has paid on time;
4. say that penalties caused by the hirer's non-payment will be transferred to them where the scheme allows, and recharged where it does not;
5. tell the hirer at booking that the vehicle is, or is not, compliant with ULEZ, clean air zone and low emission zone standards.

Whether a handling fee figure meets the fairness test is for your legal adviser, and the VAT treatment of a recharged charge or fee is set out in VAT on car hire. Glovebox lets you add a recharged charge to the booking as a post-hire charge for the hirer to pay online; it does not pay, transfer or dispute the charge itself. See the UK features page.

The checklist

1. Check every vehicle's compliance on TfL's checker and the GOV.UK clean air zone service before it joins the fleet.
2. Decide which charges you pay through accounts and which you leave to the hirer, and write it into the agreement.
3. If you pay, set up Fleet Auto Pay or Auto Pay, a clean air zone business account and a Dart Charge account, and keep the vehicle lists current.
4. Tell hirers the deadlines: midnight on the third day for ULEZ and the Congestion Charge, the sixth day for clean air zones, midnight the next day for the Dart Charge and Tyne Tunnels.
5. Keep non-compliant vehicles out of Scottish low emission zones, where there is no charge to pay.
6. Recharge at cost, itemised, with any handling fee stated in pounds and confirmed with your legal adviser.
7. Log every notice the day it arrives and transfer or pay within its window.

Straight answers