Silvertown Tunnel Fine Appeal UK 2026: TfL PCN Challenge Guide

The Silvertown Tunnel opened on 7 April 2025, and from that date Transport for London introduced a charging scheme covering both the new Silvertown Tunnel and the long-standing Blackwall Tunnel as a single joint user-charging scheme. A Penalty Charge Notice from TfL for non-payment of the tunnel user charge carries a face value of £180, reduced to £90 if paid within 14 days. That is a significantly higher penalty than many road user charging PCNs elsewhere in the UK, and the consequences of ignoring it are serious. But receiving a PCN does not automatically mean you are required to pay it: drivers who believe the charge was not due, that a registered exemption was not applied, that TfL's system failed to credit a payment, or that the PCN was served outside the statutory window have a clear route to challenge. Crucially, appeals for Silvertown and Blackwall Tunnel PCNs are heard by London Tribunals (the Road User Charging Adjudicators), not the Traffic Penalty Tribunal that handles charges at Dartford or the Mersey Gateway. This guide covers the legal framework, the four strongest appeal grounds, the step-by-step process, and what to do if your challenge fails.

What a Silvertown Tunnel PCN is and how it is issued

The Silvertown Tunnel links Silvertown in the London Borough of Newham to the Greenwich Peninsula in the Royal Borough of Greenwich. It runs beneath the Thames immediately east of the Blackwall Tunnel. The tunnel was developed under a Development Consent Order granted by the Secretary of State for Transport in 2018, with Transport for London as the promoting authority. Construction was funded through a public-private partnership at a cost exceeding one billion pounds, and the tunnel user charge is the mechanism by which those costs are recovered over the operational life of the concession.

The TfL Board formally approved the initial user charges, discounts, and exemptions in December 2024, following a public consultation held between July and September 2024 that received more than 5,000 responses. Charging commenced on 7 April 2025. Critically, TfL simultaneously began charging for use of the Blackwall Tunnel, which had previously been free for more than a century. Both tunnels are now operated as a joint scheme: a crossing of either tunnel in either direction during charging hours generates a single charge obligation.

There are no physical toll booths at either tunnel. ANPR cameras record every vehicle entry and exit. Drivers must pay by midnight on the third calendar day after the crossing, either via a TfL Auto Pay account (which also unlocks off-peak discounted rates) or through a one-off payment online or by phone. Charging hours are 06:00 to 22:00 every day including weekends and bank holidays, with Christmas Day as the sole exception. Outside those hours, no charge applies.

If payment has not been received by the third-day midnight deadline, TfL issues a Penalty Charge Notice to the vehicle's registered keeper. The PCN face value is £180. Payment within 14 days of the date of service printed on the notice reduces this to £90. This penalty level mirrors the TfL Congestion Charge PCN and reflects the Road User Charging Scheme (Penalty Charges, Adjudication and Enforcement) (England) Regulations 2013 framework applicable to London road user charging schemes. Only one PCN is issued per vehicle per day regardless of the number of crossings that day.

The legal framework: the Silvertown Tunnel User Charging Order and your appeal rights

The primary statutory authority for TfL's charging powers derives from the Greater London Authority Act 1999, which confers on Transport for London the power to establish road user charging schemes in Greater London. The Silvertown Tunnel User Charging Order is the subordinate instrument that establishes the specific scheme, defines the chargeable vehicles and crossing events, sets the charging structure, and designates TfL as the charging and enforcement authority.

Enforcement procedure is governed by the Road User Charging Scheme (Penalty Charges, Adjudication and Enforcement) (England) Regulations 2013, which apply specifically to London road user charging schemes. These Regulations prescribe mandatory contents for a PCN, the service requirements, the time limits for representations, and the route of appeal to an independent adjudicator. Where TfL fails to comply with the procedural requirements of the 2013 Regulations, that failure is itself a ground on which the PCN may be cancelled.

The independent appeal body for Silvertown and Blackwall Tunnel PCNs is London Tribunals, specifically the Road User Charging Adjudicators (RUCA). London Tribunals is an administrative body supported by London Councils; the adjudicators are independent of TfL. This is a different appeal body from the Traffic Penalty Tribunal, which handles road user charging appeals outside London including the Dartford Crossing and the Mersey Gateway. Appellants appealing a Silvertown PCN should navigate to londontribunals.gov.uk, not trafficpenaltytribunal.gov.uk. The same London Tribunals body handles ULEZ appeals (see our ULEZ PCN appeal guide) and bus lane PCN appeals in London (see our bus lane fine appeal guide).

Your appeal rights proceed in the following sequence. First, you must make representations to TfL within 28 days of the date of the PCN. Second, if TfL rejects your representations, it will issue a Notice of Rejection of Representations. You then have 28 days from the date of service of that Notice to appeal to London Tribunals. At every stage the PCN is frozen: no escalation or additional charges accrue while a representation or appeal is pending and TfL has been notified of it. If you do not pay and do not make representations within 28 days of the original PCN, TfL may proceed immediately to the next enforcement stage without further notice.

Four grounds on which a Silvertown Tunnel PCN can be successfully appealed

TfL's representations process and the London Tribunals adjudication consider specific statutory and factual grounds. The four strongest grounds for Silvertown and Blackwall Tunnel PCN challenges are set out below, each with the evidence required to substantiate the argument.

Ground 1: User charge paid but not credited to the journey

The most common basis for a successful TfL road user charging appeal is where the driver did pay the charge, whether via Auto Pay, online payment, or by phone, but TfL's system failed to record or credit the payment to the correct journey. This may occur where a payment reference was entered incorrectly, where a vehicle registration was not correctly associated with an Auto Pay account, or where a system processing error occurred on TfL's side.

Evidence to gather: a confirmation email or reference number from TfL showing the payment was submitted, with a timestamp that pre-dates the PCN issue date; bank or credit card statements showing the payment was processed; a screenshot of your TfL Auto Pay account showing the vehicle is registered and that the relevant crossing date was logged; and any TfL correspondence (online account messages, email, or letter) acknowledging the account was active. Where you paid manually, the transaction reference from the TfL payment portal or the operator phone line is particularly valuable. An adjudicator who can see that payment was made and received before the PCN was issued will normally allow the appeal.

Ground 2: Vehicle exempt or registered for a qualifying discount

The TfL Board-approved discount and exemption package for the Silvertown and Blackwall Tunnel scheme includes several categories of vehicle that are not subject to the full charge or are entirely exempt. Exempt vehicles include those with a disabled tax class or used by Blue Badge holders who are registered with TfL. Zero-emission capable private hire vehicles licensed by TfL and on an active booking are exempt. TfL-licensed taxis and buses are also exempt. Emergency service vehicles are similarly exempt.

Discount categories, operational at scheme launch, include a 50 per cent discount for low-income residents in 13 East and South-East London boroughs who are in receipt of certain means-tested benefits, a discount for eligible small businesses, sole traders, and charities in qualifying boroughs, and reimbursement arrangements for NHS staff and patients eligible for the NHS reimbursement scheme.

Where a PCN is issued for a vehicle that was registered for an exemption or discount with TfL at the time of the crossing, the ground is that no charge, or a reduced charge only, was due. Evidence to gather: a copy of your TfL online account confirmation that the exemption or discount registration was accepted and active on the date of the crossing; the V5C logbook showing a disabled tax class if applicable; the Blue Badge itself, if claiming the Blue Badge holder exemption; documentary evidence of benefit receipt or income if claiming a low-income residents discount; and any TfL email or account reference confirming the exemption application was approved. If your exemption or discount application was pending at the time of the crossing but had not yet been formally approved, the position is more complex and may require additional evidence of the application date.

Ground 3: PCN served outside the statutory 28-day window or with procedural defects

Under the Road User Charging Scheme (Penalty Charges, Adjudication and Enforcement) (England) Regulations 2013 that govern London road user charging schemes, TfL must serve a PCN within 28 days of the date of the alleged contravention. If the PCN is posted more than 28 days after the recorded crossing date, it is out of time and should be cancelled. Similarly, the Regulations prescribe mandatory information that the PCN must contain. Where required information is absent or materially inaccurate, the PCN may be defective and liable to cancellation on procedural grounds.

Evidence to gather: the PCN itself, recording both the date of the alleged contravention and the date of service (typically the date of posting plus two working days by statutory convention); the envelope in which the PCN arrived, retaining any postmark visible on the envelope; and a note of the actual date of receipt. Calculate the gap between the contravention date and the service date. A gap greater than 28 calendar days is a procedural breach under the 2013 Regulations. Where the PCN omits mandatory information, identify precisely which statutory requirement has not been met and note the specific Regulation that requires it.

Ground 4: Contravention did not occur or vehicle misidentified

ANPR systems are reliable but not infallible. Where a driver believes their vehicle was not present at either tunnel on the date stated in the PCN, whether because the vehicle was elsewhere, because of an ANPR misread of a similar plate, or because the vehicle's plates have been cloned, the ground for appeal is that the contravention as described did not occur with respect to this registered keeper's vehicle.

Evidence to gather: contemporaneous records placing the vehicle away from the Silvertown or Blackwall Tunnel at the time in question, including dashcam footage with a GPS timestamp, fuel receipts, workplace or home CCTV showing the vehicle stationary, a statutory declaration if the vehicle was sold before the contravention date, or a witness statement from someone who can confirm the vehicle's location. If plate cloning is suspected, a police crime reference number and a statutory declaration to that effect are important. Photographs showing your vehicle's registration plate in clean, correct, undamaged condition are useful to accompany a request that TfL produce the ANPR image from the alleged crossing for comparison. London Tribunals adjudicators can direct TfL to produce photographic evidence, and a comparison between the two images may itself resolve the matter.

How to appeal a Silvertown Tunnel PCN step by step

The appeal process for a Silvertown or Blackwall Tunnel PCN follows three mandatory sequential stages. You cannot proceed directly to London Tribunals without first completing the representations stage with TfL.

Stage 1: Representations to TfL. You have 28 days from the date of service of the PCN to submit your representations. Representations should be made via TfL's online challenge portal, accessible through the TfL website at tfl.gov.uk under the Silvertown and Blackwall Tunnels section. You may also write to TfL by post at the address printed on the PCN. Do not pay the PCN before or during this stage: payment is treated as an admission of liability and ends your right to challenge the charge. The PCN is suspended while TfL considers your representations. TfL will issue a decision, typically within 56 days of receiving your representations. If TfL cancels the PCN, the matter ends. If TfL rejects your representations, it issues a Notice of Rejection of Representations together with details of how to proceed to London Tribunals.

Stage 2: Appeal to London Tribunals. Once you have received the Notice of Rejection, you have 28 days from the date of service of that notice to submit an appeal to the Road User Charging Adjudicators at London Tribunals. The appeal form is the form included with the Notice of Rejection. Send this directly to London Tribunals at the address on the form: do not send it to TfL. You may choose a personal hearing, a postal hearing (determination on written submissions without attendance), or a telephone or video hearing. London Tribunals will notify TfL of the appeal. TfL will submit its evidence to the adjudicator. You will receive a copy and an opportunity to submit any further evidence or response within the timetable set by the tribunal office. The PCN remains frozen throughout this stage.

Stage 3: Adjudicator determination. The adjudicator will consider all submitted evidence and issue a written determination. If the appeal is allowed, the PCN is cancelled and any amount already paid is refunded by TfL. If the appeal is refused, you will be given a period (typically 14 days) to pay the outstanding charge. Both parties are bound by the determination. A further statutory review on a point of law is available in very limited circumstances but is not a general avenue of appeal against a factual determination.

Missing the 28-day representations window, or the 28-day tribunal appeal window, forfeits your right to challenge and allows TfL to proceed to the Charge Certificate and subsequent enforcement stages without further opportunity for you to contest the charge.

Template appeal letter

Use the template below when writing to TfL to make representations against a Silvertown or Blackwall Tunnel PCN. Adapt the bracketed sections to your specific circumstances. Submit via the TfL online challenge portal where possible; if writing by post, send by tracked delivery and retain a copy of everything submitted.

[YOUR FULL NAME]
[YOUR ADDRESS]
[DATE]

Transport for London
Road User Charging
[Address as printed on PCN]

RE: REPRESENTATIONS AGAINST PENALTY CHARGE NOTICE
PCN Reference: [as shown on your PCN]
Vehicle Registration: [your vehicle registration]
Date of Alleged Contravention: [date shown on PCN]
Tunnel: [Silvertown Tunnel / Blackwall Tunnel — as stated on PCN]

Dear Sir or Madam,

I write to make formal representations against the above-referenced Penalty Charge Notice issued in respect of an alleged failure to pay the tunnel user charge.

GROUND OF CHALLENGE:
[State your ground clearly, for example:
- "I paid the tunnel user charge for the crossing in question. I attach payment confirmation reference [XXXX] dated [date], along with my TfL account screenshot and bank statement confirming the transaction was processed prior to the PCN being issued."
- "My vehicle holds a registered Blue Badge holder exemption with TfL (reference [XXXX]). The vehicle should not have been subject to the tunnel user charge on the date in question. I attach my Blue Badge, V5C confirming disabled tax class, and TfL's written confirmation of the registered exemption."
- "The PCN bears a contravention date of [date] but was served on [date]. This exceeds the 28-day statutory service period under the Road User Charging Scheme (Penalty Charges, Adjudication and Enforcement) (England) Regulations 2013."
- "My vehicle was not at the Silvertown or Blackwall Tunnel on [date]. I attach evidence placing the vehicle at [location] at the relevant time. I believe there has been an ANPR error or that my vehicle's plates have been cloned (police crime reference: [XXXX])."]

EVIDENCE ENCLOSED:
[List each document clearly, numbered]
1. [Description of document 1]
2. [Description of document 2]
3. [Description of document 3]

I respectfully request that TfL cancel the PCN and, if any payment has already been made, that a full refund be issued.

Yours faithfully,
[YOUR SIGNATURE]
[YOUR PRINTED NAME]

Evidence checklist

• The original PCN, noting the PCN reference number, contravention date, tunnel named, and date of service.
• The envelope in which the PCN was received, with any visible postmark (to verify service date against statutory deadline).
• TfL payment confirmation: email receipt, transaction reference from the online payment portal, or bank statement showing a TfL tunnel charge debit on or before the relevant payment deadline.
• TfL Auto Pay account screenshot showing the vehicle's registration is linked, the account is active, and the crossing in question appears (or should appear) in the journey history.
• V5C vehicle registration certificate for the vehicle, confirming registered keeper details and vehicle classification.
• Blue Badge and V5C showing disabled tax class, if claiming the Blue Badge holder exemption.
• TfL written confirmation (email or account letter) of any exemption or discount registration, including the reference number and the date the registration was approved.
• Evidence of qualification for a low-income residents discount: proof of residence in a qualifying East or South-East London borough (council tax bill or utility bill) and evidence of benefit receipt (DWP letter, Universal Credit screenshot, or equivalent).
• Dashcam footage, GPS track, workplace CCTV, fuel receipts, or other contemporaneous records placing the vehicle away from the tunnel at the time of the alleged crossing, if disputing that the contravention occurred.
• Police crime reference number and statutory declaration if plate cloning is alleged.
• All previous correspondence with TfL relating to this PCN, including online portal submissions, email exchanges, and any automated TfL responses.
• Notice of Rejection of Representations, if proceeding to London Tribunals appeal.

Published Silvertown Tunnel appeal outcomes data

The Silvertown Tunnel user charging scheme launched on 7 April 2025. At the time of writing, the scheme has been operational for approximately one year, which is insufficient for a full annual cycle of published appeal statistics to be publicly available from London Tribunals for the Silvertown and Blackwall Tunnel scheme specifically.

London Tribunals publishes annual statistical data for road user charging schemes it adjudicates. For the London Congestion Charge and ULEZ schemes, which operate under the same Road User Charging Adjudicators and use the same procedural rules, published statistics consistently show that a meaningful proportion of appeals that reach the tribunal are allowed each year. The Silvertown and Blackwall Tunnel scheme uses the same enforcement and adjudication framework, and there is no structural reason why appeal outcomes should differ materially from those patterns.

TfL does not separately publish statistics on representations resolved at the informal stage (cancelled before reaching London Tribunals). Where a genuine ground exists, statistics from analogous schemes under the same adjudicators suggest there is a realistic prospect of a successful outcome, particularly for payments credited in error, established exemptions not applied, and out-of-time PCNs. Appellants should not be deterred by the higher face value of the Silvertown PCN: the appeal procedure is the same regardless of the penalty amount, and the adjudicator's decision is based on the merits of the case.

For context on how London Tribunals handles road user charging appeals more broadly, see our guide on ULEZ PCN appeals, which uses the same appeal body and comparable procedural rules.

What happens if your appeal is rejected

If the London Tribunals adjudicator refuses your appeal, the PCN stands and must be paid within the period specified in the adjudicator's determination, normally 14 days from the date of the decision. At that point three options remain.

First, you may pay the outstanding amount within the time specified. The PCN amount does not increase as a result of having appealed and lost, provided you pay within the determination's payment window. This is the most straightforward resolution and ends any further enforcement action.

Second, in limited circumstances, a statutory review of the adjudicator's decision is available on a point of law, not on the facts. This requires a separate formal application arguing that the adjudicator applied the law incorrectly. It is not a rehearing of the evidence. Legal advice should be sought before pursuing a statutory review, as it is a specialist process with specific procedural requirements.

Third, if the outstanding amount is not paid, TfL will issue a Charge Certificate adding 50 per cent to the amount due. If that Certificate remains unsatisfied, TfL may apply to register the debt at the Traffic Enforcement Centre at Northampton County Court. Debt registration creates a civil court record and authorises TfL to instruct enforcement agents to recover the amount from your goods. Enforcement agent action carries its own fees, which are added to the sum owed. The total liability for an unpaid Silvertown PCN that reaches the enforcement agent stage is therefore substantially higher than the original £180.

Citizens Advice provides free guidance on enforcement agent rights and what they may and may not seize. If you are facing enforcement action and are in financial difficulty, Citizens Advice can also help you understand your options. For other London PCN types and appeal routes, see the UK Fines and Appeals hub.

Sources and verification

• Transport for London, penalty charges for Blackwall and Silvertown tunnels: tfl.gov.uk/modes/driving/silvertown-blackwall-tunnels-charge/penalty-charges-for-blackwall-and-silvertown-tunnels
• Transport for London, challenge a Penalty Charge Notice: tfl.gov.uk/modes/driving/silvertown-blackwall-tunnels-charge/challenge-a-penalty-charge-notice
• London Tribunals, Road User Charging Adjudicators: londontribunals.gov.uk/ruc/understanding-enforcement-process
• Road User Charging Scheme (Penalty Charges, Adjudication and Enforcement) (England) Regulations 2013: legislation.gov.uk/uksi/2013/1783/contents
• Greater London Authority Act 1999, road user charging powers: legislation.gov.uk/ukpga/1999/29/contents
• TfL Board, Silvertown and Blackwall Tunnels user charge approval, December 2024: tfl.gov.uk/corporate/publications-and-reports/board-papers
• Citizens Advice, dealing with bailiffs and enforcement agents: citizensadvice.org.uk/debt-and-money/enforcement-action/bailiffs/

This article is for informational purposes only and does not constitute legal advice. Always verify current procedures and time limits with the relevant authority before submitting an appeal.

Frequently asked questions

What is a Silvertown Tunnel PCN?

A Silvertown Tunnel PCN is a civil penalty issued by Transport for London when a vehicle uses the Silvertown Tunnel or the Blackwall Tunnel during charging hours (06:00 to 22:00 daily) without paying the required user charge by midnight on the third day after the crossing. The face value is £180, reduced to £90 if paid within 14 days of service. The penalty applies to both tunnels under the joint user-charging scheme that came into effect on 7 April 2025. It is not a criminal fine and does not affect your driving licence.

How long do I have to appeal a Silvertown Tunnel fine?

You have 28 days from the date of service of the PCN to submit representations to TfL. If TfL rejects your representations and issues a Notice of Rejection, you then have a further 28 days from the date of service of that Notice to appeal to London Tribunals (the Road User Charging Adjudicators). The PCN is frozen throughout both stages, meaning no escalation occurs while your challenge is under consideration. Missing either deadline allows TfL to proceed directly to the Charge Certificate and subsequent enforcement stages.

Are Silvertown Tunnel appeals heard by the same body as Dartford Crossing?

No. This is an important distinction. Dartford Crossing (Dart Charge) appeals are heard by the Traffic Penalty Tribunal (TPT), which handles road user charging schemes outside London. Silvertown and Blackwall Tunnel appeals are heard by London Tribunals, specifically the Road User Charging Adjudicators (RUCA), which is the independent adjudicator for Transport for London's charging schemes including the Congestion Charge and ULEZ. Appellants should use londontribunals.gov.uk, not trafficpenaltytribunal.gov.uk, for Silvertown PCN appeals.

What residents discount applies to the Silvertown Tunnel charge?

Low-income residents of 13 East and South-East London boroughs who are in receipt of qualifying means-tested benefits are eligible for a 50 per cent discount on the standard user charge, reducing a car peak crossing to approximately 75 pence. To benefit from the discount it must be registered with TfL before the crossing. Where a PCN is issued for a vehicle whose registered discount was active and on the TfL system at the time of the crossing, the discount was not properly applied, and this is a ground for representations. Check the TfL website for the current list of qualifying boroughs and benefits, as these may be subject to periodic review.

What happens if my Silvertown Tunnel appeal is rejected?

If London Tribunals refuses your appeal, the PCN stands and must be paid within the period specified in the adjudicator's determination (typically 14 days). If it remains unpaid, TfL will issue a Charge Certificate adding 50 per cent to the outstanding amount, then apply to register the debt at the Traffic Enforcement Centre (Northampton County Court). This authorises enforcement agents (bailiffs) to recover the debt from your goods. A civil court record is also created. A statutory review on a point of law is available in limited circumstances but is not a general re-appeal route. For other London road penalty types, see the UK Fines and Appeals hub.