Posting in case this helps anyone else in the same boat — this scenario seems increasingly common and I wanted to document it publicly while I'm still going through the process.
THE UNDERLYING ISSUEMy AutoPay account remained
active throughout. Some payments continued to process successfully. What had actually happened was that coverage for certain charges had
silently ceased for my vehicle, without any notification from TfL. When I checked my account, everything looked fine. The first I knew of a problem was when enforcement letters started arriving.
It appears the Auto Pay service can partially fail — e.g. coverage dropping for specific charging schemes — while the account remains outwardly operational. No warning, no email, nothing. This is a
significant service failure in my view, and from searches through this forum and elsewhere, I'm not the first person it's happened to.
WHAT I'VE DONE1. Immediate remedial actionAdded the vehicle back to AutoPay as soon as I became aware of the issue.
2. Submitted representations on every PCNCiting:
- The silent nature of the AutoPay failure
- No notification from TfL
- Good-faith belief the service was operating (supported by the fact other payments were processing)
- Immediate remedial action on discovery
- Medical mitigation for lateness where relevant (with GP letter pending)
3. Silvertown/Blackwall Tunnel scheme — four PCNs cancelled 
TfL cancelled
four PCNs on discretion via a Notice of Acceptance. The letter expressly confirmed the vehicle was
"not automatically covered for the date of travel" because it had been added after the date of contravention. So TfL is
implicitly acknowledging that AutoPay coverage can lapse without the account holder knowing. This is important — it's effectively an admission.
4. Fifth Silvertown PCN — "Late Representation Disregard"My representation here was late due to ill health, and I received a Late Representation Disregard letter. I've now used the "Update your representation" function to respond with additional evidence and a fuller supporting letter, asking them to reconsider on grounds of consistency (same underlying cause as the four cancelled) and mitigating circumstances.
5. Four Congestion Charge PCNs — representations submittedIncluding two at Charge Certificate stage. Submitted representations online asking for discretionary cancellation on the same grounds as the Tunnels cancellations. Representation reference confirmed and enforcement suspended while under review.
KEY PRACTICAL POINTS FOR OTHERS- If your AutoPay appears active and some payments are processing, do NOT assume full coverage. Log in and check which vehicles are registered for which schemes, specifically.
- If you get a PCN and believe AutoPay should have covered it: check your AutoPay account BEFORE responding, and screenshot everything.
- Don't pay — paying forfeits your right to appeal.
- Submit representations online (reference numbers are issued; enforcement is suspended on submission).
- Attach any Notice of Acceptance you receive for related PCNs — the consistency argument is genuinely powerful.
- If you're late because of ill health, a GP letter is worth pursuing. GPs can write letters linking current presentation to previously documented clinical history where applicable.
- If a representation is disregarded as late but you're invited to provide additional evidence, "Update your representation" is the right function — not "Challenge" (which starts over).
- Keep every piece of correspondence. Screenshot every confirmation page.
STILL IN PROGRESSI'll update this thread when decisions come back. I want to see how TfL handle the consistency point — i.e. whether they cancel four PCNs on discretion for an AutoPay failure and then enforce further PCNs on the same vehicle for the same failure. That's the real test.
Happy to answer questions from anyone else going through the same thing.
