Welsh 20mph Speeding Fine: The Three Defences That Actually Work

The Welsh 20mph Default Has Generated £1.3m in Fines

Since the Restricted Roads (20 mph Speed Limit) (Wales) Order 2022 came into force in September 2023, the default speed limit on most restricted roads in Wales dropped from 30mph to 20mph. By April 2025, GoSafe (the Welsh police road-safety partnership) had recorded 62,500 detections generating an estimated £1.3 million in Fixed Penalty Notices, with the political fallout leading to the Ken Skates review in 2024 and a partial roll-back of some 20mph designations from 2025.

The legal challenge environment is now richer than it has been at any point since the rule was introduced. Three defences in particular are succeeding:

1. Signage non-compliance under the TSRGD 2016 — many 20mph designations rolled out faster than the signage was updated
2. Road wrongly classified as restricted — some routes were defaulted to 20mph that arguably should have stayed 30mph, and the Skates review identified specific corridors for reversal
3. Mitigation grounds — minor exceedances (21-24mph) attract a discretionary speed-awareness course offer that avoids the £100 fine and 3 points

Understanding the Letter You Received

GoSafe issues two types of notice for 20mph excess:

Most letters are at the COFP stage. The £100 figure is fixed under section 53 of the Road Traffic Offenders Act 1988. The 3 penalty points stay on your licence for 4 years.

Defence 1: Signage Non-Compliance Under TSRGD 2016

The Traffic Signs Regulations and General Directions 2016 specify exactly how speed limit changes must be marked:

• Terminal signs (the round signs at the start of the limit) must be present and visible
• Repeater signs within the zone (the smaller round signs at intervals)
• Carriageway markings ("20" painted on the road) at key positions

If any of these are missing, faded, blocked by foliage, or not in compliance with the regulated dimensions, the speed limit is arguably unenforceable on that stretch.

In Wales, many 20mph designations were rolled out faster than the signage program. A 2024 review by the Welsh Government identified hundreds of roads where signage compliance was below the TSRGD threshold.

Evidence to gather:

• Photos of the terminal signs at every entry point to the section where you were detected
• Photos of the repeater signs within the zone (or absence thereof)
• Carriageway markings photos
• Comparison to TSRGD specs (sign sizes, mounting heights, retroreflectivity)

If a sign is missing or non-compliant, cite the relevant TSRGD diagram and reference number in the representations.

Defence 2: Road Wrongly Classified

The Restricted Roads Order 2022 applies the 20mph default to restricted roads as defined by the Road Traffic Regulation Act 1984. A restricted road is one with a system of street lighting (lamp posts no more than 200 yards apart) — NOT every road in Wales. Some roads were defaulted to 20mph that fall outside the statutory definition.

The 2024 Skates review identified specific corridors marked for return to 30mph, including:

• Main arterial routes between towns
• Roads with no pedestrian crossings or other risk factors
• Routes where the 20mph designation reduced bus journey times disproportionately

If your detection was on a road that has been identified for return to 30mph (check the council's signage program update), the representations can argue the 20mph designation was disproportionate or wrongly applied.

Defence 3: Mitigation and the Course Offer

Welsh police forces operate the National Speed Awareness Course (NSAC) as a diversionary disposal under the Association of Chief Police Officers guidelines. Drivers detected at the lower end of the excess range (typically 21-24mph in a 20mph zone) are offered the course as an alternative to the £100 + 3 points.

The course costs around £90, takes half a day, and crucially results in NO points on your licence. For drivers with existing points, near the totting-up threshold (12 points = automatic disqualification under section 35 of the Road Traffic Offenders Act 1988), the course is materially valuable.

If your speed was 25mph or more, the course offer is usually withdrawn. At 30mph+ a court summons is more likely than a COFP.

Some drivers initially miss the course offer because they reply by post with a defence letter rather than engaging with the COFP form correctly. If the offer is in the original letter, accept it within 28 days — it cannot be re-offered after that.

Step 1: Choose Your Route

Use this decision tree:

1. Speed 21-24mph and no existing points concerns → accept the speed-awareness course
2. Speed 21-29mph, existing points, want to avoid more → accept the course if offered
3. Speed 30mph+ or court summons received → defence by signage / classification grounds
4. Speed 21-29mph but missing or non-compliant signage → defence by signage grounds, save the course for fallback
5. Speed 21-29mph, no existing points, no defence grounds, want to fight on principle → court hearing, expect to lose, accept the consequences

Step 2: If Defending — Draft the Representations

Skeleton:

```

[Your name]

[Address]

[Date]

GoSafe Wales

[Address from COFP]

COFP reference: [from the letter]

Representations against Conditional Offer of Fixed Penalty

1. I do not contest that the vehicle [VRM] was at the location and

speed alleged.

1. The 20mph speed limit at that location is not enforceable due to

non-compliance with the Traffic Signs Regulations and General

Directions 2016, specifically:

[a) Terminal sign missing / non-compliant at point X

b) Repeater signs absent for [distance] within the section

c) Carriageway markings worn / not present]

1. I attach photographs taken on [date] showing the deficiencies.

1. I respectfully request that the COFP be withdrawn.

Yours faithfully,

[Signature]

```

Step 3: If GoSafe Rejects

The next step is either to accept the £100 + 3 points or to request a court hearing. The court hearing route has costs:

• Magistrate's court fee: typically £0 for the defendant in summary cases
• Loss of half a day's earnings
• Risk of higher fine (court can impose up to £1,000 under section 17 RTRA 1984) and costs award if you lose unreasonably
• A successful court defence keeps the points off your licence and may not even result in a fine

For most Welsh 20mph cases at 21-24mph, the speed-awareness course is by far the lowest-risk option if available. Court should be reserved for cases where the signage non-compliance is documented and clear-cut.

Numbers That Matter

• Welsh 20mph default in force: since 17 September 2023
• Detections to April 2025: ~62,500 (GoSafe)
• Total revenue: ~£1.3 million
• FPN amount: £100 + 3 points
• Speed-awareness course cost: ~£90, no points
• Court window: 28 days from COFP
• Magistrate's court maximum fine: £1,000 under s.17 RTRA 1984
• Penalty points retention: 4 years for speeding

Related Reading

• Yellow Box Junction PCN Appeal — sister moving-traffic offence
• Bus Lane Emergency Vehicle Defence — bus-lane moving-traffic defence
• Single Code of Practice 2026 Rules — broader enforcement context