Yes, they are correct. As you didn't receive the Notice to Owner you can submit a Witness Statement once the council register the debt at TEC. They will then send out an Order for Recovery. From now on, you must be proactive, and from the end of the period for payment of the CC, ring-up TEC about every 7-10 days quoting the PCN Number to find out if it's registered or not. You don't need the paper OfR in your hand in order to submit your WS. You can download the form from TEC. (Traffic Enforcement Centre).
TEC will revert the matter to the NtO stage at which point you can submit reps or pay. Note that if you submit the WS before the debt is registered, it will be rejected.