Enforcement company
Trace Enforcement: Council Bailiffs or Private Parking?
Trace Enforcement Services, trading as Trace Group, do two genuinely different jobs. One is statutory civil enforcement for local authorities. The other is recovering unpaid private parking charges, which is not enforcement in the legal sense at all.
- Council bailiffs, or private parking?
- Whether they can force entry
- What the council enforcement fees cost
- Rated Exceptional
- 40,000+ Supported
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What are Trace contacting you about?
May not be suitable in all circumstances. Our initial advice is free, but fees may apply and your credit rating may be affected if you opt for a debt solution.
Company details
| Type | Enforcement company |
|---|---|
| Registered name | Trace Enforcement |
Key facts
- Two capacities
- Council enforcement, or private parking recovery
- Private parking charge
- No enforcement power until a court judgment
- Council enforcement entry
- Not forced on a first visit
- Several council debts
- £79 each, but only one £247 visit fee
On this page 18 sections
Mixing the two up is the most common source of confusion about a letter from this firm, and the rules that apply to you depend entirely on which one your letter concerns.
Who are Trace Enforcement?
Trace Enforcement Services Limited, trading as Trace Group, are based in Oldham and operate nationally. The firm is listed as a member of the Civil Enforcement Association (CIVEA) and is recorded in the Enforcement Conduct Board's accreditation directory since October 2023, for its certificated civil enforcement work. Both are checkable independently with CIVEA and the ECB.
Company registration details such as the Companies House number, registered office and directors have not been independently verified for this build and are not stated here. Check the company number printed on your own letter against the public register if you need to confirm it.
Are Trace bailiffs or debt collectors, and does it depend on the letter?
Yes, it genuinely depends on the letter, more so than for most firms on this site.
Where Trace act for a local authority enforcing council tax or a parking penalty, they are enforcement agents working under Schedule 12 of the Tribunals, Courts and Enforcement Act 2007, with statutory power to take control of goods once a liability order or warrant of control is in place.
Where Trace act to recover an unpaid private parking charge, for a private landowner or a parking management company rather than a council, they have no bailiff powers at all. A private parking charge is a civil contract claim, not a fine, and the only route to enforce it is to sue in the county court and obtain a judgment. Until that happens, a letter from Trace about a private parking charge is a request for payment, not a demand backed by legal enforcement power, however firmly it is worded.
If you are unsure which kind of letter you have, see bailiffs and debt collectors.
Working out which Trace letter you have
| The letter concerns | Who instructed Trace | Legal footing |
|---|---|---|
| Council tax arrears | Local council | Liability order, Schedule 12 enforcement powers |
| A council parking or traffic penalty | Local council | Warrant of control, Schedule 12 enforcement powers |
| A private parking charge notice | Private landowner or parking company | Civil debt only, no enforcement power yet |
The paperwork usually gives this away. A council enforcement case references a liability order or a warrant number and a council tax or vehicle registration reference. A private parking case references a car park, a charge notice number and a parking operator's name rather than a council. If in doubt, contact the alleged creditor named on the notice rather than assuming.
Council tax enforcement
A council cannot pass a case to Trace without first obtaining a liability order from the magistrates' court. That order confirms the sum is due and unlocks enforcement; it is not authority to force entry into your home.
Regulation 34(3) of the Council Tax (Administration and Enforcement) Regulations 1992 stops a council applying for a liability order more than six years after the sum first became due. It does not put an expiry date on an order already granted. See council tax bailiffs and liability orders.
Council parking and traffic penalties
An unpaid decriminalised parking or traffic penalty is registered at the Traffic Enforcement Centre, and the council obtains a warrant of control. If you never received the original notice, had already appealed, or were not the registered keeper at the time, the centre may provide a route back. For an ordinary council parking penalty anywhere in England, or a council bus-lane or moving-traffic penalty outside London, the usual route is a witness statement on form TE9, with TE7 available if you are out of time. For a TfL Congestion Charge, LEZ or ULEZ penalty, the statutory-declaration route uses PE3, with PE2 if late. London-borough or TfL bus-lane and moving-traffic cases sit under separate London legislation, so check the form enclosed with the order rather than assuming either route. See the Traffic Enforcement Centre and PE3 and TE9 forms.
Entry rules for either council debt are the same: no forced entry to a home on a first visit.
Private parking charges: not enforcement, and no power to force anything
If Trace's letter concerns a private parking charge notice, none of the enforcement powers described elsewhere on this page apply, because no court order exists yet. Trace cannot take control of goods, cannot force entry, and cannot add statutory enforcement fees to a private parking debt at this stage.
What the operator can do is issue a letter before claim and then, if you do not respond or pay, start a county court claim. If that claim succeeds and remains unpaid, only then could enforcement become possible, and it would need to go through the same court process as any other county court judgment, not through Trace acting as an enforcement agent. See letter before claim and debt collectors and what they can do if you want the fuller picture of what a firm can and cannot do at this pre-court stage.
If you believe the private parking charge itself is wrong, the appeal route (through the operator's own process, and potentially POPLA or the Independent Appeals Service depending on the trade body involved) is separate from anything on this page and should be pursued directly with the operator or the relevant appeals body.
Can Trace force entry, for a council enforcement case?
Not for council tax or a council parking or traffic penalty, on a first visit to your home. Entry must be peaceable, through a door you choose to open or one already unlocked. You are not obliged to answer the door.
An agent who cannot get in peaceably has to leave, though an accessible vehicle parked outside can still be taken into control. The narrow exception is paragraph 19A of Schedule 12, allowing reasonable force for re-entry only where a controlled goods agreement has already been signed and then broken. See when bailiffs can force entry.
What each stage costs, for council enforcement cases
Fees on statutory enforcement work are fixed by regulation and identical across every firm; they do not apply to a private parking charge that has not yet reached enforcement.
| Stage | What it means | Fixed fee |
|---|---|---|
| Compliance | Case received, Notice of Enforcement issued, no visit yet | £79 |
| Enforcement | An agent has attended, or taken steps to take control of goods | £247 plus 7.5% of any sum above £1,900 |
| Sale or disposal | Goods removed for sale | £116 plus 7.5% of any sum above £1,900 |
These figures apply to instructions taken on under the scale in force from 1 May 2026.
If Trace hold more than one council debt against you
Regulation 11 of the Taking Control of Goods (Fees) Regulations 2014 allows the £79 compliance fee to be charged once for each enforcement power, but the £247 enforcement fee and the £116 sale fee may only be charged once, where the debts can reasonably be enforced together.
The Notice of Enforcement and your deadline
Before goods can be taken into control on a council enforcement case, you must be sent a Notice of Enforcement, allowing at least 14 clear days for instructions under the rules from 1 May 2026. A recognised debt advice provider can request an extension to a minimum of 28 clear days unless the debt is a non-eligible business debt.
Goods, vehicles and what is out of reach
Only goods belonging to the debtor can be taken into control on an enforcement case, and only once one exists. Regulation 4 of the Taking Control of Goods Regulations 2013 keeps certain essentials out of reach: everyday clothing and bedding, household equipment a home needs to run, items needed for medical care or for looking after a child, a disabled person or an older person, domestic pets and assistance dogs, and a vehicle displaying a valid disabled person's badge. Tools or equipment genuinely needed for work are exempt only up to £1,350 in total.
A car outside is often the first thing considered. Ownership decides most disputes: a Motability vehicle is leased rather than owned, a car on hire purchase or PCP may belong to the finance company, and a vehicle belonging to someone else in the household is not the debtor's to lose. See what bailiffs can take and can bailiffs take my car.
Arranging payment
For a genuine council enforcement debt, an arrangement typically takes the form of a controlled goods agreement: listed items stay with you while you keep to the terms. Check every item is actually yours and that the balance and fees are correct before signing. See controlled goods agreements.
For a private parking charge, an arrangement is a straightforward payment plan agreed directly with Trace or the parking operator, and carries none of the controlled-goods consequences described above, because no enforcement power exists yet.
If you cannot afford to pay
Say so early and support it with figures. Free help preparing an income and expenditure statement is available from National Debtline, StepChange and Citizens Advice.
Disputing the debt
For a council enforcement debt, take a dispute to the council, not only to Trace. Trace collects what it was instructed to collect and cannot rewrite a council tax account or cancel a penalty charge.
For a private parking charge, dispute it with the parking operator directly, or through the relevant appeals service, since Trace at this stage is only chasing payment on the operator's instruction.
Vulnerability and welfare support
Tell Trace and the instructing creditor (the council, or the parking operator) as early as possible, in writing where you can. Vulnerability is judged on individual circumstances: serious illness, disability, bereavement, pregnancy, age related difficulty, language or literacy barriers, recent trauma and household crisis can all be relevant.
Outcomes can include additional time, communication adjustments, a more affordable arrangement, or a temporary hold. None of this cancels the debt.
Checking a Trace letter is genuine
Use contact details obtained independently, from Trace Group's own website, the council's published list of enforcement agents, or the parking operator's own website, rather than a number printed only on an unexpected letter.
Before paying, confirm which debt the payment settles, which of the two capacities described on this page Trace is acting in, and what stage the case has reached. Get a reference and keep the receipt.
Complaining about Trace
First, Trace's own complaints procedure. State the date, the reference, what happened, and the specific point you rely on.
Second, the party who instructed them: the council for an enforcement case, or the parking operator for a private charge. This is often the more effective step, since only the instructing party can correct the underlying account.
Third, the oversight route, for the certificated enforcement side of Trace's work: the Enforcement Conduct Board, since Trace is recorded in its accreditation directory. A dispute over an individual agent's certificate is a separate matter for the county court that issued it. A complaint about a private parking charge is a matter for the operator's trade body appeals scheme rather than the ECB.
Keep dates, correspondence, photographs and the names of everyone you speak to.
Where to start
- Work out which capacity Trace are acting in: council enforcement, or private parking recovery.
- If it is council enforcement, check the stage and fees against the tables above.
- If it is a private parking charge, remember no enforcement power exists yet; a court judgment would be needed first.
- If the debt is wrong, raise it with the council or the parking operator, not only with Trace.
- If it is correct but unaffordable, prepare figures and make a realistic offer.
- If you are vulnerable, say so now, in writing.
How a Trace Enforcement debt could reach bailiffs
A debt collector cannot send bailiffs. Only a court can, and only after a judgment. These are the stages in between, and each one is easier to deal with than the one after it.
-
A collector asks you to pay
No court is involved yet. A debt collection agency has no enforcement powers at all, it cannot enter your home, take goods or add enforcement fees. This stage can last a long time.
-
A County Court claim is issued
The creditor, or the company that bought the debt, asks the court to decide you owe the money. This is the stage where the deadlines start to matter, and where a defence such as limitation has to be raised.
-
Judgment is entered (a CCJ)
If you do not respond in time, judgment is entered by default, without anyone examining whether the debt was correct. A CCJ stays on your credit file for six years.
-
A warrant or writ of control is issued
An unpaid judgment can be enforced. This is the document that authorises enforcement agents to attend, and the point at which a debt collection matter becomes a bailiff matter.
-
Enforcement agents can attend you are here
Now there are real powers: peaceable entry, taking control of goods, and statutory fees of £79, £247 and £116 at defined stages. This is the stage the earlier ones exist to avoid.
Which bailiffs would actually attend
That depends on the amount and on what kind of debt it is, and the rule is set by article 8 of the High Court and County Courts Jurisdiction Order 1991 rather than by the creditor's preference.
- Under £600, the judgment can only be enforced in the county court, so county court bailiffs attend under a warrant of control.
- £5,000 or more, and not a regulated credit agreement, it can only be enforced in the High Court, so High Court enforcement officers attend under a writ of control. They charge on a different and higher fee scale.
- Anything else, including a regulated credit agreement of any size, may be enforced in either court.
Whether your agreement is regulated by the Consumer Credit Act 1974 changes which court can enforce it. Credit cards, loans, overdrafts and catalogue accounts usually are; council tax, traffic penalties and court fines are not, and those reach enforcement by a different route entirely.
If several debts are enforced together
This happens often, particularly where one company has bought several of your accounts, or where a council has more than one liability order against you. The enforcement agent is instructed on all of them at once and deals with them on the same visit.
The fees do not simply multiply, and this is where people are most often overcharged. Where the agent is instructed under more than one enforcement power against the same debtor, and those powers can reasonably be exercised at the same time, regulation 11 of the Taking Control of Goods (Fees) Regulations 2014 splits the treatment:
- The £79 compliance fee may be charged for each enforcement power. Several of these is correct.
- The £247 enforcement fee and the £116 sale fee may each be charged only once, however many debts are involved.
So three debts enforced together should cost three compliance fees and one enforcement fee, £484, rather than three separate lots of £326. If you have been charged an enforcement fee for each debt on a single visit, that is worth challenging in writing.
The saving depends on the debts genuinely being enforceable at the same time. Where an agent legitimately attends on separate occasions for unrelated matters, separate fees can apply, so it is worth checking the dates and references on the fee breakdown before challenging it.
Not sure which one is contacting you? How to tell from the paperwork
Frequently asked questions
Are Trace Enforcement bailiffs or debt collectors?
It depends on the letter. For council tax and council parking or traffic penalties, they are enforcement agents with statutory powers under Schedule 12 of the Tribunals, Courts and Enforcement Act 2007. For a private parking charge, they have no bailiff powers at all; it is a civil debt that would need a county court judgment before any enforcement could begin.
Can Trace force entry into my home?
Not for a council tax or council parking penalty case on a first visit, and not at all for a private parking charge, since no enforcement power exists on that route until a court judgment is obtained.
Can Trace take my belongings over a private parking charge?
Not yet, and not without a county court judgment first. Enforcement agents can only take control of goods once a liability order, warrant of control, or equivalent county court enforcement route is in place.
What are Trace's fees for a council enforcement case?
£79 at compliance, £247 once an agent attends or takes steps to take control of goods, plus 7.5% of anything above £1,900, and £116 if goods are removed for sale. These fees do not apply to a private parking charge that has not reached enforcement.
I have more than one council debt with Trace. Do the fees multiply?
Only partly. The £79 compliance fee applies per enforcement power, but the £247 enforcement fee and £116 sale fee may each be charged once where the debts can reasonably be enforced together.
How do I dispute a private parking charge from Trace?
Raise it with the parking operator named on the original charge notice, or through the relevant trade body appeals scheme, rather than only with Trace. Trace is acting on the operator's instruction and cannot itself cancel the charge.
Sources
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Tribunals, Courts and Enforcement Act 2007, Schedule 12, paragraph 10
legislation.gov.uk
An enforcement agent may take control of goods only if they are goods of the debtor.
Checked 2026-08-17 -
Tribunals, Courts and Enforcement Act 2007, Schedule 12, paragraph 17
legislation.gov.uk
Where paragraph 18, 18A, 19 or 19A applies, an enforcement agent may if necessary use reasonable force to enter premises or to do anything for which the entry is authorised.
Checked 2026-08-17 -
Tribunals, Courts and Enforcement Act 2007, Schedule 12, paragraph 19A
legislation.gov.uk
This paragraph applies if these conditions are met— (a) the enforcement agent has power to enter the premises under paragraph 16; (b) the enforcement agent has taken control of the goods by entering into a controlled goods agreement with the debtor; (c) the debtor has failed to comply with any provision of the controlled goods agreement.
Checked 2026-08-17 -
Taking Control of Goods Regulations 2013, regulation 4
legislation.gov.uk
items or equipment (for example, tools, books, telephones, computer equipment and vehicles) which are necessary for use personally by the debtor in the debtor's employment, business, trade, profession, study or education, except that in any case the aggregate value of the items or equipment to which this exemption is applied shall not exceed £1,350… assistance dogs (including guide dogs, hearing dogs and dogs for disabled persons), sheep dogs, guard dogs or domestic pets; a vehicle on which a valid disabled person's badge is displayed.
Checked 2026-08-17 -
Taking Control of Goods Regulations 2013 (SI 2013/1894), regulation 13
legislation.gov.uk
The enforcement agent may not take control of goods of the debtor before 6 a.m. or after 9 p.m. on any day.
Checked 2026-08-17 -
Taking Control of Goods (Fees) Regulations 2014, Schedule 1 Table 1, as amended by SI 2026/366
legislation.gov.uk
Compliance stage £79.00 0%; Enforcement stage £247.00 7.5%; Sale or disposal stage £116.00 7.5% — percentage of sum to be recovered exceeding £1900.
Checked 2026-08-17 -
Taking Control of Goods Regulations 2013, regulation 6, as amended by SI 2026/366
legislation.gov.uk
notice of enforcement must be given to the debtor not less than 14 clear days before the enforcement agent takes control of the debtor's goods. Where, before the expiration of the period of notice indicated in the notice of enforcement, a request is submitted by a debt advice provider on behalf of the debtor, the minimum period of notice referred to in paragraph (1) must be extended to a minimum of 28 clear days before the enforcement agent takes control of the goods. The extension under paragraph (1A) does not apply where the debt is non-eligible business debt. Where the period referred to in paragraph (1) or (1A) includes a Sunday, bank holiday, Good Friday or Christmas Day that day does not count in calculating the period.
Checked 2026-08-17 -
Taking Control of Goods (Fees) Regulations 2014, regulation 11
legislation.gov.uk
The enforcement agent may recover the compliance stage fee in respect of each enforcement power to which the instructions relate… the fixed fee for each stage may be recovered only once regardless of the number of enforcement powers to which the instructions relate.
Checked 2026-08-13 -
Council Tax (Administration and Enforcement) Regulations 1992, regulation 34(3)
legislation.gov.uk
no application may be instituted in respect of a sum after the period of six years beginning with the day on which it became due
Checked 2026-08-13 -
Form PE2: application to file a statutory declaration out of time (statutory-declaration regimes: TfL Congestion Charge/LEZ/ULEZ and PD 75 para 5.1(1))
HM Courts and Tribunals Service
Application to file a statutory declaration out of time
Checked 2026-08-17 -
Form PE3: statutory declaration, unpaid penalty charge (TfL Congestion Charge/LEZ/ULEZ and other statutory-declaration regimes under PD 75 para 5.1(1))
HM Courts and Tribunals Service
I did not receive the Notice to Owner / Enforcement Notice / Penalty Charge Notice… I made representations about the penalty charge to the local authority concerned within 28 days of the service of the Notice to Owner / Enforcement Notice / Penalty Charge Notice, but did not receive a rejection notice. I appealed to the Parking / Traffic Adjudicator within 28 days of service of the rejection notice, but have had no response to my appeal… Important: Filing a false declaration knowingly and wilfully is a criminal offence under Section 5 of the Perjury Act 1911 and you may be imprisoned for up to 2 years or fined or both.
Checked 2026-08-17 -
Form TE9: witness statement — traffic enforcement order outside London boroughs, or a parking charge in a London borough
HM Courts and Tribunals Service
Use this form to challenge a traffic enforcement order outside London boroughs or a parking charge in a London borough.
Checked 2026-08-21 -
Form TE7: apply for more time — traffic enforcement order outside London boroughs, or a parking charge in a London borough
HM Courts and Tribunals Service
Use this form to ask for more time to challenge a court order ('order of recovery') for traffic enforcement charges outside London boroughs, or a parking charge in a London borough.
Checked 2026-08-21 -
Civil Enforcement of Road Traffic Contraventions (England) General Regulations 2022, regulation 23 (invalid notices — witness statement within 21 days)
legislation.gov.uk
This regulation applies where— (a) a county court makes an order under regulation 22, (b) the person against whom it is made ("P") makes a witness statement complying with paragraph (2), and (c) that statement is served on the county court which made the order, before the end of— (i) the period of 21 days, beginning with the date on which notice of the county court's order is served on P, or (ii) such longer period as may be allowed under paragraph (4). A witness statement must state one and only one of the following— (a) that P did not receive the enforcement notice; (b) that P made representations to the enforcement authority under regulation 5 of the 2022 Appeals Regulations but a notice of rejection was not received from that authority in accordance with regulation 6 of those Regulations; (c) that P appealed to an adjudicator under regulation 7 of those Regulations against the rejection by the enforcement authority of representations made under regulation 5 of those Regulations but— (i) P did not receive a response to the appeal, (ii) the appeal had not been determined by the time the charge certificate was served, or (iii) the appeal was determined in P's favour; (d) that P has paid the penalty charge to which the charge certificate relates. Where this regulation applies— (a) the order made under regulation 22 is deemed to have been revoked, (b) the charge certificate is deemed to have been cancelled, (c) in the case of a witness statement including a statement under paragraph (2)(a), the enforcement notice to which the charge certificate relates is deemed to have been cancelled, and (d) the district judge must serve written notice of the effect of this regulation on P and on the enforcement authority concerned. Service of a witness statement including a statement under paragraph (2)(a) does not prevent the enforcement authority from serving a fresh enforcement notice.
Checked 2026-08-21 -
Practice Direction 75 — Traffic Enforcement, paragraphs 5.1-5.2 (statutory declaration vs witness statement; forms PE2/PE3/TE7/TE9)
Ministry of Justice (Civil Procedure Rules)
a completed application notice (form PE2 (Application to File a Statutory Declaration Out of Time) may be used for applications relating to statutory declarations and form TE7 may be used for applications relating to witness statements); and (2) a completed— (a) statutory declaration in form PE3 (Statutory Declaration – unpaid penalty charge); or (b) witness statement in form TE9.
Checked 2026-08-21 -
Road User Charging (Enforcement and Adjudication) (London) Regulations 2001, regulation 19 (invalid notices — statutory declaration within 21 days; Congestion Charge/LEZ/ULEZ)
legislation.gov.uk
(b) the person against whom it is made makes a statutory declaration complying with paragraph (2); and (c) that declaration is, before the end of the period of 21 days beginning with the date on which notice of the county court's order is served on him, served on the county court which made the order.
Checked 2026-08-21
Next step
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