Penalty fare for travel outside London Transport zones on Oyster Card

[Watershed]

Oyster cards are quite primitive really and only have four bits (1s or 0s) that can be used to define the zones for journey history/charging purposes. Hence a maximum of 15 zones can exist in the Oyster system (2 to the power of 4, less one for "no zone" presumably).

Gatwick simply had the good fortune to come first in terms of the Oyster rollout, and so the highest zones are used for travel to Gatwick. The only way of expanding Oyster to be valid at Stansted would be "align" the fares (i.e. increase them to the extortionate Stansted rate), which I'm sure would be popular...

 

[WesternLancer]

Oyster cards are quite primitive really and only have four bits (1s or 0s) that can be used to define the zones for journey history/charging purposes. Hence a maximum of 15 zones can exist in the Oyster system (2 to the power of 4, less one for "no zone" presumably).

Gatwick simply had the good fortune to come first in terms of the Oyster rollout, and so the highest zones are used for travel to Gatwick. The only way of expanding Oyster to be valid at Stansted would be "align" the fares (i.e. increase them to the extortionate Stansted rate), which I'm sure would be popular...

Thanks for such an informative explanation.

 

[Kilopylae]

Hasn't Oyster been around long enough that London residents at least should be aware that unless it's a detailed exception, it doesn't extend beyond the boundaries of Greater London?

I don't think most people know off the top of their head where the boundary of Greater London is. If I didn't live in Hillingdon I wouldn't have been able to tell you that Heathrow was within Greater London whilst Gatwick wasn't. They're completely interchangeable to most people.

 

[etr221]

Hasn't Oyster been around long enough that London residents at least should be aware that unless it's a detailed exception, it doesn't extend beyond the boundaries of Greater London?

I don't think most people know off the top of their head where the boundary of Greater London is. If I didn't live in Hillingdon I wouldn't have been able to tell you that Heathrow was within Greater London whilst Gatwick wasn't. They're completely interchangeable to most people.

I do wonder how many people - even those who perhaps should know, rather than the nerds who actually study such things - could actually just say, and swear to it, from any station whence PAYG (of one or or other system) is valid, whither it (and by what route) is actually valid.
Case in point: National Rail Enquiries has just quoted me a fare of £15.70 by contactless for 2258 from Clapham Junction, change at Wokingham, to Reading arrive 0015.

I suspect, Clapham Junction or Wimbledon, where you have four PAYG systems (SWR's and GTR's KeyGo, as well as Oyster and CPAY) are probably worst (and, with TfL Tubes and Trams to consider, Wimbledon the very worst) for this sort of exercise.

Getting back to Tottenham Hale, looking at the 'Tap Tap and Away' posters, it's not at all clear (without reading the small print) that they only apply to Contactless, not Oyster - if I didn't know, I doubt I'd have appreciated that they didn't.

And - as signs being in 'several languages' have been mentioned, the images posted only show them in Spanish and Italian. Why only two? And why those two?

 

[MikeWh]

And - as signs being in 'several languages' have been mentioned, the images posted only show them in Spanish and Italian. Why only two? And why those two?

I must admit I thought there were 3 extras, but I wasn't paying attention between taking the pic and posting. There are, of course, 3 languages if you include English. I've no idea why Spanish and Italian - are they the most popular destinations from Stansted? It is better than just English, however random the languages are.

 

[Cdd89]

I must admit I thought there were 3 extras, but I wasn't paying attention between taking the pic and posting. There are, of course, 3 languages if you include English

Perhaps you're thinking of the Gatwick Express, which does English, Spanish, Italian and French?

 

[Harratt4]

Hasn't Oyster been around long enough that London residents at least should be aware that unless it's a detailed exception, it doesn't extend beyond the boundaries of Greater London?

Given that in common parlance oyster and contactless are synonymous I think the boundary of Greater London is a bit of a red herring here. It is only relatively recently that there has been any difference in validity between an Oyster and contactless card and I don't think that new distinction has been widely talked about.

 

[MikeWh]

Given that in common parlance oyster and contactless are synonymous I think the boundary of Greater London is a bit of a red herring here. It is only relatively recently that there has been any difference in validity between an Oyster and contactless card and I don't think that new distinction has been widely talked about.

From my site: https://oysterfares.com/south-east-rail-pay-as-you-go-with-contactless/

A brief history​

On September 16th 2014 TfL launched the ability to use contactless cards and devices to make PAYG journeys wherever Oyster was accepted. This was a game changer because you no longer needed to worry about topping up. Nearly 5 years later on August 29th 2019 Brookmans Park became the first station to accept contactless but not Oyster. A few weeks later the same arrangements were extended to Luton Airport Parkway, and then to Welwyn Garden City in November. These were the pilots for the major extension for TfL’s pre-Elizabeth line service to Reading which went live on January 2nd 2020.

So you're saying that more than half the time that contactless has been a thing is "relatively recently"? I agree that the difference hasn't been talked about enough, but TfL have certainly been talking about it with respect to Reading.

 

[Harratt4]

From my site: https://oysterfares.com/south-east-rail-pay-as-you-go-with-contactless/


So you're saying that more than half the time that contactless has been a thing is "relatively recently"? I agree that the difference hasn't been talked about enough, but TfL have certainly been talking about it with respect to Reading.

The fact that I had no idea, perhaps proves my point

 

[Kilopylae]

The fact that I had no idea, perhaps proves my point

Quite!

 

[MrJeeves]

Hence a maximum of 15 zones can exist in the Oyster system (2 to the power of 4, less one for "no zone" presumably).

There is still a "Zone F" (1111) which was originally intended for Oyster out to Reading on Elizabeth Line but wasn't used. As far as I know, "Zone F" remains available if a final extension to Oyster was ever desired, but I doubt it will ever be used, especially if Railcards on contactless are finally looking to be on the horizon.

I would guess that a "Zone 0" is used for things like buses and trams.

 

[CmWS]

Hi,

Just wanted to provide an update on this case. I submitted my 2nd appeal, and have just got a letter back saying that this appeal was rejected. They said:

"I acknowledge the points raised by yourself and this case has been fully reviewed. Whilst I acknowledge the
points made in your appeal, it is the passenger's responsibility to check that Oyster payment is accepted for their
whole journey prior to boarding the train. With regard to your point about signage, under the Amended
Regulations 2022, Greater Anglia is not required to provide this additional signage. The penalty fare warning signs
that are required under the current regulations are displayed throughout the station and are fully compliant with
the statutory requirements.
Being confident that AS have followed the correct procedure, I can confirm that our initial decision remains and
payment of the outstanding balance of £72.00 is now due."

I really do not agree that the penalty fare warnings are "displayed throughout the station and are fully compliant with the statutory requirements". I found only two notices about penalty fares in the entire station (or at least visible when transferring from the underground) - as you can see from the picture both of these are completely obscurred in some way or another. One is behind the black box on the left, and the other is on the wall behind the person in the middle (also obscurred by the big sign when approaching from the underground). I did not even notice them until another user on here pointed them out to me; I did not spot them at all on my second visit to the station. There is no way that these are adequate if I can't find them when I am directly looking for them.

I intend to submit a third appeal on this matter. I would really appreciate any advice anyone can give me for this, I really don't feed like this is a fair outcome.

Thanks

 

[AlterEgo]

Trying to suggest that a sign is not compliant because a passenger is standing in front of it is laughable. It's on the wall, at eye level, where it should be, and is readily visible except for the fact you took the picture when someone is stood in front of it. You need only one to satisfy the regulations. That location appears sensible and normal for a penalty fares sign

The test of adequate signage is not that literally every passenger be forced to read it unavoidably, there simply has to be a minimum of one sign readily visible, which in plain language means "can be seen". I could not tell you where the PF notices are at Rugby, a station I use regularly, but that doesn't mean they aren't compliant.

All you can do is make the same argument to the third appeal panel to see if they will accept it, but I must say the objection to the signage is not well founded in my view.

 

[Watershed]

I would go back to this previous thread which was created regarding very similar circumstances and copy some (if not all) of the wording from that. That appeal was successful in the end.

Trying to suggest that a sign is not compliant because a passenger is standing in front of it is laughable. It's on the wall, at eye level, where it should be, and is readily visible except for the fact you took the picture when someone is stood in front of it. You need only one to satisfy the regulations. That location appears sensible and normal for a penalty fares sign

The test of adequate signage is not that literally every passenger be forced to read it unavoidably, there simply has to be a minimum of one sign readily visible, which in plain language means "can be seen". I could not tell you where the PF notices are at Rugby, a station I use regularly, but that doesn't mean they aren't compliant.

All you can do is make the same argument to the third appeal panel to see if they will accept it, but I must say the objection to the signage is not well founded in my view.

If the drafters of the Regulation merely meant "can be seen", they would not have included the adjective "readily". That suggests it must have a certain degree of prominence. I don't think a sign that's merely on the left hand side of a wide gateline, often hidden by a member of gateline staff standing in front of it, can be regarded as "readily visible". If you enter at the middle of the gateline it simply wouldn't be in your field of vision.

There might be more of an argument about the sign that's hidden by the person standing at the gates in the picture attached above, but we would need to see a clearer shot to say. In any case there is high chance the wording on it is non-compliant.

 

[AlterEgo]

There might be more of an argument about the sign that's hidden by the person standing at the gates in the picture attached above, but we would need to see a clearer shot to say. In any case there is high chance the wording on it is non-compliant.

They only need one sign to be readily visible, the one on the wall in the middle of will definitely almost certainly fit that requirement.

 

[Watershed]

They only need one sign to be readily visible, the one on the wall in the middle of will definitely almost certainly fit that requirement.

The Regulation says:

displayed at sufficient locations around the station so that at least one notice is readily visible to passengers prior to boarding a train at the station

The way I read that is that at least one notice needs to be readily visible to all passengers, not just some passengers. Otherwise there would be no point including this sentence and they could just leave it with what Regulation 8(2) says:

a notice complying with the requirements of paragraph 1 of Part 1 of Schedule 1 (“a standard notice”) must be displayed at that entrance

But again we are somewhat guessing in the dark without a picture of what the sign actually says in terms of wording, and its location and size.

 

[CyrusWuff]

The exact requirement in the PF regs where a Compulsory Ticket Area is not involved is:

(2) Where any entrance onto a platform at the station is not the entrance to, or situated within, a compulsory ticket area, a notice complying with the requirements of paragraph 1 of Part 1 of Schedule 1 (“a standard notice”) must be displayed at that entrance.

Traditionally that has been interpreted as meaning the notice(s) should be displayed on the unpaid side of a gateline.

The regs also state:

(4) Standard notices and compulsory ticket area notices must also be displayed at sufficient locations around the station so that at least one notice is readily visible to passengers prior to boarding a train at the station, including passengers changing from one train to another train.

 

[CmWS]

Hi, I am planning to submit my third appeal on this case this evening. I have copied below what I intend to send; it is heavily based on this https://www.railforums.co.uk/threads/stansted-airport-fines.253779/page-3#post-6451904 as people have suggested I follow. I have ammended it for Oyster Card rather than contactless.

A few points I would like advice on:
- The third photo attached (red "oyster card is not valid" sign) - as this is not technically a penalty fare notice, I can't find anything about it in the regulations
- Is there an argument to be made than no notice is displayed before entering the compulsory ticket area?

Thanks!

######################################################################################

Background

This is my third appeal in relation to Penalty Fare Notice [redacted]. Further background information can be found in my original appeal submissions.

My appeal is based on Regulation 16(3)(a) - that “the penalty fare was not charged in accordance with the requirements of these Regulations;” based on the failure of Greater Anglia to meet the notice requirements specified in Regulation 8.

My appeal is also based on Regulation 16(3)(d) that “there are compelling reasons why, in the particular circumstances of the case, the appellant should not be liable to pay the penalty fare.”.

Relevant sections of the Regulations

Regulation 6(2)(b) states that a passenger must not be charged a Penalty Fare if “at the time when, and at the station where, the passenger boarded the train… the requirements for the display of notices specified in regulation 8 were not satisfied;”

The relevant sections of Regulation 8 are as follows:

"8.—(1) The requirements for the display of notices are as follows.
(4) Standard notices and compulsory ticket area notices must also be displayed at sufficient locations around the station so that at least one notice is readily visible to passengers prior to boarding a train at the station, including passengers changing from one train to another train"

The relevant sections of paragraph 1 of Schedule 1 are as follows:

“1.—(1) A standard notice must contain—
(c)the wording “Please buy your ticket before you travel otherwise you may be charged a Penalty Fare”,



Regulation 16(3)(a) grounds for appeal – Tottenham Hale Station notices

I submit the notice at Tottenham Hale Station does not meet the requirements of the Penalty Fare Regulations. I attach photographs that I took of the warning notices at Tottenham Hale Station on 09:54am on 22/09/2026.


Assuming that the notices were in this form when I travelled on 10/09/2026 (Regulation 16(4) provides that the burden of proof falls on the operator to disprove this assumption), these photographs demonstrate that the notice at Tottenham Hale Station is deficient for the following reason:

• The notice is only located on the left-hand side of the wide gate and is not in the field-of-view for passengers entering from the middle of the gate, therefore is not ‘readily visible’ to passengers transferring from the London Underground, as required by Regulation 8(4).
• The notice is easily obscured by a member of gateline staff standing in front of it or opening the black box that can be seen in photograph 1, therefore is not ‘readily visible’ or compliant with Regulation 8(4).
• The notice does not use the form of wording required by sub-paragraph 1(1)(c) of Schedule 1.

The required form of wording is:

- “Please buy your ticket before you travel otherwise you may be charged a Penalty Fare”

The notice states:

- “Please buy your ticket before you travel, otherwise you may have to pay a Penalty Fare of at least £100”.

This wording has been included in quotation marks in the Regulations and therefore it is clear that the precise form of wording is required in order for the notice to be legally compliant.

No discretion is granted to the operators to amend or paraphrase this form of wording. I note that, in contrast, other sub-paragraphs of this provision do permit operators discretion over the form of wording to use on notices - for example, paragraph 1(1)(e) which uses the formulation ‘wording which indicates’. However, paragraph 1(1)(c) very clearly and intentionally does not permit operators any flexibility on this point. Failure to use the prescribed wording therefore renders the notice non-compliant with the Regulations.

The wording required by sub-paragraph 1(1)(da) of Schedule 1, “A Penalty Fare is £100 plus the price of the full single fare applicable for your intended journey. However, if it is paid within 21 days, the Penalty Fare is reduced to £50 plus the price of the single fare applicable”, is required in addition to the wording required by sub-paragraph 1(1)(c) of Schedule 1, not instead of, and therefore the failure of the notice to use the prescribed wording in sub-paragraph 1(1)(c) of Schedule 1 renders this notice non-compliant.


Regulation 16(3)(d) appeal - compelling reasons not liable to pay the penalty fare

Furthermore, I submit that there are compelling reasons that I should not be liable to pay the penalty fare. I submit that I made an honest error, and that the confusing ticketing requirements on my route contributed to my mistake. In addition, I have reason to believe my experience is indicative of wider issues on this route and sharp practice by Greater Anglia.

My failure to purchase a ticket was a genuine error; I did not intentionally avoid paying my fare. This is evidenced by the fact that I used my Oyster Card to touch in at Tottenham Hale Station (demonstrating an intention to pay) and by my proactive engagement with a ticket officer immediately upon becoming aware of the issue.

I believe that this route is a particularly confusing ticketing system and that Greater Anglia are profiting from passengers’ lack of understanding. There has been publicity regarding the number of penalty fares issued on this route before. I have corresponded with London Travel Watch, who inform me that they are aware of penalty fare issues on this route.

There are also many stories and reviews available online of passengers who believe they have behaved honestly and diligently but have been ‘caught out’ by this route. Many of these individuals will be visitors to this country and therefore particularly susceptible to making this mistake due to lack of familiarity with England’s geography, railway ticketing system, and/or language.

The following factors contributed to my own confusion: (i) the “TAP, TAP & AWAY” notices displayed prominently around the entrance to the Stansted Express are misleading regarding the use of Oyster card as a valid form of payment, (ii) Oyster card payment is accepted at the train station for travel to other major London airports (and I used my Oyster card to travel to London Gatwick on 28/08/2026), (iii) I was able to ‘touch in’ at Tottenham Hale Station without issue, and (iv) the airport is named London Stansted so I believed it to be part of the London Oyster PAYG area.

In this context, I note the comments made by the Minister of State for Transport at the time the Regulations were enacted: "Rail users should make every effort to get the right ticket for their journey, but if you make an honest mistake you should feel confident that the appeals system will recognise this and treat you fairly.”.

I do not believe it would be fair for me to have to pay a penalty fare, given my honest behaviour, the circumstances of my mistake and the known issues on this route.



Conclusion

Regulation 17(4) provides that “If the relevant Appeal Panel, after considering an appeal under this regulation, concludes that any ground specified in regulation 16(3) applies, it must, subject to paragraph (7), allow the appeal.”

The evidence I have provided demonstrates that the penalty fare I received was not charged in accordance with the Regulations, due to Greater Anglia’s failure to comply with Regulation 8(4) and paragraph 1(1)(c) of Schedule 1.

The Regulations are extremely clear on this point. Notices must use the exact form of wording set out in the relevant provision of the Regulations. Failure to do so means that the notices do not comply with the Regulations. If the notices do not comply with the Regulations, a penalty fare must not be charged.

Therefore I submit that the Appeals Body is required under Regulation 17(4) to allow my appeal and to disallow my appeal would be an error of law.

If the Appeals Body were minded to disallow my appeal (which I hope will not be the case), I would encourage it to take legal advice in relation to the interpretation of these provisions in order to inform its decision and would request that details of its legal analysis is included in the decision.

Further or in the alternative, I submit that Regulation 16(3)(d) applies for the reasons set out above and ask the Appeals Body to find that there are compelling reasons I should not be liable to pay the penalty fare.

 

[30907]

Some initial points, as no-one else has replied.

1. Members of this forum have been raising the paragraph 1(1)(c) issue for as long as I remember. I cannot remember a successful appeal based on this though.

2. If the only PF notice relevant to access through the gates is the one shown in your photo 1, then it is neither readily visible NOR (your query #2) visible before you use the gates. (BTW don't call it a Compulsory Ticket Area, it isn't). I think you have a strong argument there.

3. Notices stating that Oyster is not valid (your query #1) are not covered by the regulations; they are, however, relevant to some of your claimed mitigation.

 

[SuspectUsual]

Further background information can be found in my original appeal submissions.

Don’t assume the person reading your third appeal knows the slightest thing about the previous two, other than that they were rejected. Third appeals are supposed to be adjudicated by totally different people. This is your last chance to make your case and you need every relevant point to be made completely in this appeal