Civil Enforcement Bailiff Fees Wrongly Charged? How to Challenge the £75 / £235 / £110 Stack

The Fees Are Capped, Not Negotiated

When a Civil Enforcement Agent (the modern statutory name for a bailiff) is instructed to recover a council parking debt or a County Court Judgment, they may add fees to the underlying debt — but only at three specific points in the process, and only at the capped amounts set by the Taking Control of Goods (Fees) Regulations 2014. Anything beyond that is unlawfully charged.

The three permitted stages and amounts:

If a bailiff company has added fees that breach these caps, charged a stage that did not occur, or charged fees before the underlying statutory trigger was met, you can challenge them under regulation 13 of the 2014 Regulations or via a CPR Part 85 detailed assessment in the court.

Common Overcharges to Look For

These are the patterns that regularly produce successful fee challenges in 2026:

1. Compliance fee charged twice — a bailiff company instructed for two related debts cannot stack a £75 compliance fee on each if both were within the same enforcement instruction
2. Enforcement fee charged before first attendance — the £235 enforcement-stage fee only crystallises when an enforcement agent actually attends. A doorstep letter or phone call does not count
3. Compliance fee added before NoE served — fees only attach once a valid statutory Notice of Enforcement has been served with 7 clear days' notice. Letters before the NoE cannot charge the £75 stage
4. 7.5% percentage uplift on under-£1,500 debts — the percentage applies only to balances over £1,500. Many parking-debt enforcements should not include it at all
5. Sale fee without a sale — the £110 sale-stage fee requires actual removal or sale of goods. A vehicle being clamped on the highway without removal does not necessarily trigger the sale stage
6. Multiple enforcement-stage charges for the same debt — only one £235 applies per debt regardless of how many attendances are made

Step 1: Get the Full Fee Breakdown

Under regulation 8(1) of the 2014 Regulations, the enforcement agent must provide a full fee breakdown on request. If you do not have one, write:

```

Dear Sirs,

Reference: [bailiff company reference]

Underlying debt: [council PCN reference / County Court judgment number]

Pursuant to regulation 8 of the Taking Control of Goods (Fees)

Regulations 2014, I request a full itemised breakdown of all fees

applied to my account, including:

1. The compliance fee, with the date of the Notice of Enforcement
2. Each enforcement-stage fee, with the date of the corresponding

attendance and the agent's certificate number

1. Any sale-stage fee, with the date of removal or sale
2. Any percentage uplift applied to the underlying debt amount
3. VAT applied to each line

Yours faithfully,

[Your name]

```

Send by recorded delivery. They must respond within a reasonable time. Keep the receipt.

Step 2: Compare the Breakdown to the Statutory Caps

For a typical parking-debt enforcement (debt under £1,500), the lawful maximum fee stack is:

• Compliance: £75 + £15 VAT = £90
• Enforcement (if attendance occurred): £235 + £47 VAT = £282
• Sale (if removal / sale occurred): £110 + £22 VAT = £132
• Total maximum: £504 on top of the original debt

If your breakdown exceeds this, or includes a stage that did not occur, the surplus is challengeable.

For debts over £1,500, the 7.5% uplift applies on the excess at enforcement and sale stages. So a £2,500 debt would have:

• Compliance: £75 + VAT
• Enforcement: £235 + (£1,000 × 7.5%) + VAT = £310 + £62 VAT = £372
• Sale: £110 + (£1,000 × 7.5%) + VAT = £185 + £37 VAT = £222

Step 3: Send the Challenge Letter

Once the breakdown shows an overcharge:

```

Dear Sirs,

Reference: [bailiff company reference]

I have reviewed the fee breakdown provided on [date] and identify the

following items as not chargeable under the Taking Control of Goods

(Fees) Regulations 2014:

1. [Specific item, eg "Compliance fee charged twice on related debts"]
2. [Specific item, eg "Enforcement-stage fee charged before any

attendance occurred — first attendance recorded as [date]"]

I require these items to be removed from the account and any sums

already paid to be refunded within 14 days, failing which I will:

(a) Apply to the court that issued the warrant for a detailed

assessment of fees under CPR Part 85

(b) Refer the matter to the Enforcement Conduct Board for

investigation

(c) Where applicable, complain to the Civil Enforcement Association

Yours faithfully,

[Your name]

```

Step 4: Escalation Routes if the Bailiff Refuses

If the bailiff company does not refund within 14 days, the options are:

1. Enforcement Conduct Board — the independent oversight body for civil enforcement in England and Wales. Free to use. Investigates fee disputes and bailiff conduct.
2. CIVEA (Civil Enforcement Association) — the trade body for most major bailiff firms. Internal complaints process. Less independent than the ECB but useful for member firms.
3. CPR Part 85 detailed assessment — apply to the court that issued the warrant for a detailed assessment of the fees. Fee currently £108. Successful applications result in a court order for refund.
4. Information Commissioner's Office — if the bailiff company processed personal data unlawfully in pursuing the fees (eg shared with third parties without lawful basis), a separate ICO complaint.

The ECB route is the best balance of cost and effectiveness for most parking-debt fee disputes. They prefer to resolve disputes informally with the bailiff company before formal investigation.

Step 5: If You've Already Paid the Overcharge

Refunds of overcharged fees are possible after payment but require active pursuit:

• Write to the bailiff company under regulation 8 demanding refund within 14 days
• If refused, file in the small claims court for repayment plus interest at the County Courts Act 1984 statutory rate (8% currently)
• The bailiff company is usually the defendant; the underlying creditor (council, operator) is usually not a party to a fee dispute

The small-claims threshold is £10,000 — every parking-debt fee dispute is comfortably within it. Use form N1 at your local County Court hearing centre.

What Bailiff Companies Cannot Do Even at Capped Fees

Even when fees are correctly charged at the statutory caps, the bailiff is still constrained by:

• Permitted hours of attendance: 06:00 to 21:00, not Sundays or bank holidays (reg 13 TCG Regs 2013)
• Vulnerable categories: cannot take goods essential to work, disabled mobility, or in domestic-abuse circumstances (Schedule 12, TCE Act 2007)
• No forced entry on first attendance for parking or low-value debts (Schedule 12, paragraph 14)
• No fee for "letters" or "phone calls" — only the three statutory stages
• No threatening conduct — breaches are reportable to the ECB and, in serious cases, the Information Commissioner's Office and the police

See our DCBL doorstep visit stop letter guide for the door-side script and the pre-NoE letter that often prevents enforcement-stage fees from being incurred in the first place.

Numbers That Matter

• Compliance stage cap: £75 + VAT = £90
• Enforcement stage cap: £235 + VAT = £282 (+ 7.5% over £1,500)
• Sale stage cap: £110 + VAT = £132 (+ 7.5% over £1,500)
• Maximum lawful fee stack (debt under £1,500): £504
• Time to request fee breakdown under reg 8: reasonable time, typically 14 days
• CPR Part 85 detailed-assessment fee: £108
• Statutory interest on refunds via small claims: 8% under County Courts Act 1984 s.69

Related Reading

• DCBL Doorstep Visit Stop Letter — pre-NoE stop letter that often prevents enforcement-stage fees
• TE9 Witness Statement Set Aside Council CCJ — stop bailiff action by setting aside the underlying order
• N244 Set-Aside Parking CCJ — private-parking CCJ set-aside that stays bailiff action
• County Court Claim Form N1 Parking Defence — engaging at the N1 stage to avoid bailiff escalation entirely