OP, clearly you are struggling so I hope my contribution will help.
Where one needs to submit a Statutory Declaration (Form PE3), to the TEC that is Out-of-Time, i.e is beyond the time period allowed after the council serve an Order for Recovery, it has to be accompanied by another form that essentially asks the court's permission to submit the SD (the Form PE3), out-of-time. This is Form PE2
So, in Form PE2, in the box section headed: -
"My reasons for filing the Statutory Declaration outside the given time are as follows:
(Do not give your reasons for appeal against the original penalty charge on this form)."
you enter what you have written about being unable to update your V5C shortly after moving address.
I have slightly altered your text
"I changed my address on 28th October 2023 but at the time, experienced issues with updating my V5C document, due to what seems to have been a DVLA system error. The result was that I was unable to update the address on both my driving license and the V5 Registration Certificate for my car. At the time, I contacted the DVLA regarding this issue and attempted to resolve it, but the V5 update did not occur as expected. I only became aware of this in February 2024, at which point I promptly updated my V5 with the correct address details. As a result of this, I did not receive the penalty notices or any of the council documents sent subsequently.
Please note that on both forms, the Applicant is the council, you are the Respondent