FOI request detail

Ulez compliancy

Request ID: FOI-0153-2324
Date published: 10 May 2023

You asked

Is every vehicle deemed as non compliant for the ulez if you hold no data on it emissions or compliance status? If you hold no emissions data or can't aquire them. Is it automatically charged and fined if entering the zone? In such case, Proof of the cars compliance can only be changed by the driver/owner of the vehicle? If a vehicle enters the zone, please provide a time scale/procedure as to when the driver can contact you to find out if they have entered the zone or not? For example a person who isn't sure if they entered the zone, how/when can they contact you to find out if they did or didn't enter the zone.

We answered

TfL Ref: FOI-0099-2324 / FOI-0100-2324 / FOI-0152-2324 / FOI-0153-2324

Thank you for your requests of 8th, 12th and 13th April 2023 - all shown further below - asking for information about the ULEZ expansion.

Your requests have been considered in accordance with the requirements of the Freedom of Information Act and our information access policy. 

Your questions are answered in turn below. Note that, for ease, I have renumbered the questions so that the numbers run sequentially.

Case ref FOI-0099-2324:

Question 1: Every sign I see doesn't mention a charge. Are there signs up that do mention a charge? If so how many and location please.

Answer: There are no signs that mention a charge.

Question 2: If so, does it mention timing of charging? Cost of charge? Exemptions of charges?

Answer: See answer to Q1 above.

Question 3: With your current/expected Ulez signage, was their any consultation or reports done on the legalities of signage. (In particular the wording of signage as from what I see, they dont mention a charge.

Answer: All signage is legal and complies with the Traffic Signs Regulations and General Directions 2016 (TSRGD). To ensure consistency with our other Road User Charging Schemes, such as the Low Emission Zone (LEZ) and Congestion Charge, we have followed the same principles for our signage since 2003. The Department for Transport (DfT) was engaged and signed off our designs.

Question 4: Was there any research/consultation on the wording of the signage? To show that it would be clear and fully understood by the public.

Answer: See answer to Q3 above. To add to that, during the design stage (which took place in 2017 and which included liaison with DfT as referenced above) we considered the use of additional messaging to that which was eventually agreed, including the potential to add instructions about paying charges. However, there is only a limited amount of messaging that can be placed on a traffic sign which can be safely read and assimilated by drivers moving at speed. For the introduction of the ULEZ scheme, where around 90% of vehicles comply and therefore do not need to pay a charge, we considered that messaging that included payment instruction was not necessary.

There is a large range of information that drivers need to know about the ULEZ scheme in terms of compliance, enforcement and payments, that it is not practical to include on a single sign. We therefore had to select the most appropriate communication channels to help drivers fully understand the scheme, and our traffic signing strategy forms part of that.

The main decisions and agreement with DfT around signage happened when the original central London ULEZ was introduced and the same principles were then followed as the scheme expanded to the area within the North / South Circular in 2021. 

Question 5: To the best of my knowledge, no signage mentions charges, timings, exemptions or ways and the amount to pay. Please supply any legislation, data, information or consultation that you have used to think that this is legal and clear signage, as to the best of my knowledge, charge or cost or payment is never mentioned.

Answer: See the answers to question 3 & 4.

Case ref FOI-0100-2324

Question 6: How is a vehicle confirmed as being compliant or not if you hold not factual data on that particular vehicle emissions? How is compliant or not decide on your database that holds no emissions data?

Answer: Please see our response to your previous request, case reference FOI-3317-2223. The key criteria we use to establish compliance is the date a vehicle is first registered as new with the DVLA. We know that all diesel cars first registered as new after 1 September 2015, and all petrol cars first registered as new after 1 January 2006 are compliant with the ULEZ standards. This is because there was a legal requirement on manufacturers to produce vehicles to Euro 4 (petrol) and Euro 6 (diesel) standards as of those dates.

Question 7: If you hold no data, how do you decide a vehicle is non compliant? What policy or guidelines do you use?

Answer: As per our answer to question 6 we use the date a vehicle was first registered as new with the DVLA. In addition, and as highlighted in our response to your previous request FOI-3317-2223, we have also set up an enquiry service which allows motorists to contact us if they believe that the compliance details we hold are incorrect. This allows them to provide information to us on their vehicle and request that we update the compliance status. If we receive information which confirms compliance we will update our records and mark the vehicle compliant. Such evidence could include a Certificate of Conformity from the vehicle manufacturer.

Question 8: On the FOI Ref: FOI-3317-2223. You mention you hold no emissions data on any tfl data base. Do you have any access to any 3rd party data base with and vehicle emissions on them? If so who and any financial agreement with them.

Answer: We have an agreement with the DVLA to receive a monthly extract of their vehicle database, which does include some emissions data as well as the date of first registration  that is used to derive compliance information. There is a financial agreement in place with the DVLA. We also have an agreement with DVSA to facilitate the passing on of information regarding Low Emission Certificates (LEC). LECs are issued by DVSA approved testing centres and confirm a vehicle’s emissions.

Question 9: As mentioned in previous TFL FOI and also on many of your websites/advertising, you mention that customers can send you proof of vehicle compliance via a V5 or CoC. Many older V5 certificates don't have the required Nox level on it and some CoCs don't have it. What happens in this instance, is your default position on this that it is non compliant?

Answer: The Low Emission Zone Scheme Order, which includes the ULEZ, states:

(2) A vehicle meets the standards required of an ultra low emission vehicle for the purposes of this Scheme if Transport for London is satisfied that the vehicle meets the emissions standards specified for that vehicle in Tables 2 to 6 of Part 2 of Annex 2.

This puts the onus on the motorist to confirm their vehicle is compliant. If there is no evidence to support this then the vehicle will be considered non-compliant and the charge will be payable.

Question 10: Is any vehicle built before the legal compliance of euro4 petrol and euro6 diesel assumed non compliant? For example a 2010 model diesel is assumed chargeable with no emissions data being held because it was manufactured before the relevant euro emission became law?

Answer: In the absence of any information confirming a vehicle is compliant; vehicles manufactured prior to the dates are considered non-compliant. The enquiry service allows motorists to contact us and provide evidence of compliance if they feel their vehicle has been incorrectly classified.  

Question 11: In some cases, vehicles built before the relevant euro emissions became law, Are classed on your checker as compliant. How is this decision made? What data is used for you to say it is compliant as you have said you hold no data.

Answer: This means we will have received evidence to confirm the vehicle is compliant despite being manufactured before the legal dates. This could be in the form of a Certificate of Conformity or other information from the manufacturer or when the DVLA hold actual vehicle emission data for the vehicle and it confirms compliance.

Question 12: In general, it seems that your position is if you don't know the vehicles ULEZ status, you charge it and then ask questions/proof of Conformity later. Feels abit like guilty until the vehicle owner proves innocence via them supply you with information. Please supply any legislation or policy saying this is the way you work and is legal, fair and justified.

Answer: See question 9.  

Case ref FOI-0152-2324

Question 13: Further to my previous request about the number of vehicle on your ulez compliancy database, you responded there were 67,654,005. Can you confirm this is the actual figure as it seems very high, with an estimate of 33,000,000 vehicles in the UK.

Answer: The DVLA data we receive contains around 51m records and includes a large number of vehicles which are currently not licenced. As we have been maintaining our vehicle registration list for over 4 years there will be vehicles which were added historically which may no longer exist. The list also contains non-UK vehicles where the compliance status is known.

Question 14: What countries are they registered in please, break down per country.

Answer: We do not capture the country a vehicle is registered, only whether it is UK or non-UK.

Question 15: Of the total cars currently on your data base, how many of these are listed as non compliant?

Answer: Our database does not record the vehicle type. Therefore we are unable to establish whether a vehicle listed on the database is a ‘car’ - as specified in the question - as opposed to a lorry, motorbike or other type of vehicle. Therefore we do not hold this information.  

Question 16: Of the total number of vehicles on your database, what was your policy/guidelines on deciding its compliance statues? As you have already told me in a previous request that you hold no emissions data.

Answer: See answer to Questions 6 and 7 above and our previous response under FOI-3317-2223

Question 17: Do you have Access to any emissions data for vehicles from any other sources? If so, what sources and any financial agreements with them, for them to supply you with data.

Answer: See answer to Question 8 above.

Question 18: Is the compliance status you decide based purely on the age?

Answer: No

Question 19: How many people have sent you copies of their V5c?

Answer: When we update a vehicle record on our database we do not record why it has been updated. Since the launch of the ULEZ in 2019 we have manually updated 57,000 vehicle records. As we do not record the reason for the update, to establish how many updates have been as a result of receipt of a V5C or Certificate of Conformity we would need to manually check each record. This is not possible within the costs limit for responding to FOI cases, as set out under section 12 of the Freedom of Information Act. Under section 12, TfL is not obliged to provide information if it would cost more than £450 to determine if that information is held, and to then locate, retrieve or extract it from elsewhere. This is calculated at a rate of £25 per hour, equivalent to 18 hours work.

Question 20: How many people have sent you a manufacturers copy of CoC?

Answer: See answer to Question 19. The same exemption applies.

Question 21: How many vehicles compliance status' have you changed due to customer proof of compliance through document they send you? If any then how many From non compliant to compliant. And compliant to non compliant.

Answer: See answer to Question 19. The same exemption applies.

Case ref FOI-0153-2324

Question 22: Is every vehicle deemed as non compliant for the ulez if you hold no data on it emissions or compliance status?

Answer: See question 9.

Question 23: If you hold no emissions data or can't aquire them. Is it automatically charged and fined if entering the zone?

Answer: See question 9

Question 24: In such case, Proof of the cars compliance can only be changed by the driver/owner of the vehicle?

Answer: No. If we receive information from a manufacturer or other source which confirms compliance we would update our records.

Question 25: If a vehicle enters the zone, please provide a time scale/procedure as to when the driver can contact you to find out if they have entered the zone or not? For example a person who isn't sure if they entered the zone, how/when can they contact you to find out if they did or didn't enter the zone.

Answer: The ULEZ operates using Automatic Number Plate Recognition technology. Each entry point to, and exit from the zone is clearly signed and as a vehicle either enters, leaves or drives within the zone its registration is recorded along with an image of the vehicle.

At the end of the third charging day after the journey, when the payment period has expired, the list of vehicles observed in the zone is compared against the vehicles for which a charge has been paid, those which are exempt from the charge or those listed on an Autopay account. Where a match is found the image and record of the vehicle is deleted. If no match is found the details are retained for enforcement purposes.

As the vehicles entering the zone are not verified until after the payment period has expired we are unable to advise motorists whether they have been into the zone.

If you wish to see if you have travelled in the zone there is a map on our website where you can clearly see the boundary and enter an postcode or street name to see if your journey will take/took you not the zone: ULEZ: Where and when - Transport for London (

If this is not the information you are looking for please do not hesitate to contact me.

Please see the attached information sheet for details of your right to appeal as well as information on copyright and what to do if you would like to re-use any of the information we have disclosed.

Yours sincerely,

David Wells
FOI Case Officer
FOI Case Management Team
General Counsel
Transport for London


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