Write to the BPA with the following formal complaint and make sure you attach copies of your original formal complaint to UKPA and their brush-off response:
Subject: Formal Complaint Against UKPA – PPSCoP Non-Conformance and KADOE Breach
Dear British Parking Association Complaints Team,
I am submitting a formal complaint against UKPA for multiple breaches of the Private Parking Single Code of Practice (PPSCoP). This complaint relates to Parking Charge Notice (PCN) [PCN Number], issued on [Date], and UKPA’s handling of my appeal. Their response includes misleading and unlawful statements that violate the PPSCoP.
UKPA’s appeal rejection falsely claimed:
"If the keeper names the driver and it subsequently emerges that the driver was not suitably insured at the material time, UKPA may consider referring the matter for criminal prosecution, a £5,000 fine, and 6–8 penalty points."
This is legally incorrect and coercive. There is no legal obligation for a keeper to name the driver. UKPA has no authority to instigate criminal proceedings or impose fines. This is a deliberate misrepresentation of authority, which is classified as a Level 4 non-conformance under Annex H of the PPSCoP.
UKPA’s letter falsely claimed that a court will assume the keeper was the driver unless they name someone else and that failing to provide the driver’s details could result in legal consequences that do not exist. These are misleading statements, in breach of Annex H (Level 3 non-conformance).
UKPA’s Notice to Keeper (NtK) is not compliant with the Protection of Freedoms Act 2012 (PoFA). It fails to specify the actual period of parking (PoFA 9(2)(a)) and does not properly invite the keeper to pay (PoFA 9(2)(e)(i)). This is a Level 2 non-conformance under Annex H.
I have already referred this matter to the DVLA for investigation into UKPA’s breach of the Keeper at Date of Event (KADOE) contract. UKPA’s failure to comply with the PPSCoP means their access to DVLA keeper data is unlawful.
I raised these issues with UKPA in a formal complaint, which they dismissed without addressing any of the breaches. Copies of my complaint and UKPA’s response are attached.
I require the BPA to:
• Investigate UKPA’s breaches of Annex H (Level 4, Level 3, and Level 2 non-conformances).
• Issue immediate sanction points.
• Confirm whether UKPA has been instructed to amend its appeal rejection templates to remove false legal threats.
Failure to address this complaint will result in further escalation to Trading Standards. I expect a full response within 14 days.
Yours sincerely,
[Your Name]
Send the following complaint to the DVLA and also include a copy of your formal complaint to UKPA and their brush-off response:
Subject: Complaint Against UK Parking Administration Ltd (UKPA) – Misuse of DVLA Data and KADOE Breach
Dear DVLA Data Complaints Team,
I am submitting a formal complaint against UKPA for breaching the Keeper at Date of Event (KADOE) contract by failing to comply with the BPA/IPC Private Parking Single Code of Practice (PPSCoP). UKPA obtained my details from the DVLA and issued Parking Charge Notice (PCN) [PCN Number] on [Date]. Their appeal rejection contained misleading and coercive statements, in breach of both the PPSCoP and consumer protection laws.
UKPA falsely claimed:
"If the keeper names the driver and it subsequently emerges that the driver was not suitably insured at the material time, UKPA may consider referring the matter for criminal prosecution, a £5,000 fine, and 6–8 penalty points."
This is completely false and designed to intimidate recipients into paying. UKPA has no authority to bring criminal proceedings, impose fines, or enforce penalty points. This is a deliberate misrepresentation of authority and a Level 4 non-conformance under Annex H of the PPSCoP.
UKPA’s Notice to Keeper (NtK) is not PoFA compliant, meaning keeper liability does not apply.
• PoFA 9(2)(a) – Fails to specify the actual period of parking.
• PoFA 9(2)(e)(i) – Fails to properly invite the keeper to pay.
Since PoFA and PPSCoP compliance is a requirement of the KADOE contract, UKPA’s use of DVLA data is unlawful.
I raised these issues in a formal complaint to UKPA, which they dismissed without addressing any of the breaches. Copies of my complaint and UKPA’s response are attached.
I request that the DVLA:
• Investigate UKPA’s misuse of keeper data.
• Suspend or review UKPA’s access to DVLA data.
• Confirm whether UKPA has been instructed to remove false legal threats from their appeal rejection templates.
UKPA’s failure to comply with PoFA and the PPSCoP renders their access to DVLA data unlawful. I expect a full response within 14 days.
Yours sincerely,
[Your Name]
You have until 19th March to submit a POPLA appeal. Before you do that, you should submit a formal complaint to UKPA which they are obliged to acknowledge and respond to. Send the following to them at complaints@ukparkingadministration.com and CC in yourself.
Subject: Formal Complaint Regarding Appeal Rejection and PPSCoP Non-Conformance
Dear UK Parking Administration,
I am submitting a formal complaint regarding your handling of my appeal for Parking Charge Notice (PCN) [PCN Number], issued on [Date]. Your appeal rejection contains multiple breaches of the Private Parking Single Code of Practice (PPSCoP), including a Level 4 non-conformance under Annex H, as well as breaches of PoFA 2012 Schedule 4. Additionally, your Notice to Keeper (NtK) contains procedural errors and non-compliances that invalidate any reliance on keeper liability, making your enforcement action unlawful.
This complaint serves as a precursor to a formal complaint to the British Parking Association (BPA) and the DVLA, as these breaches also invalidate your compliance with the KADOE contract for DVLA data access.
1. Deliberate Misrepresentation of Authority – PPSCoP Level 4 Non-Conformance
Your appeal rejection falsely claims that failing to name the driver could result in if the keeper names the driver and it subsequently emerges that the driver was not suitably insured at the material time, UKPA may consider referring the matter for criminal prosecution, a £5,000 fine, and 6–8 penalty points. This is entirely false, misleading, and a coercive attempt to pressure payment under duress.
• There is no legal obligation for the registered keeper to name the driver in a private parking matter.
• There is also no basis in law for a criminal prosecution, fine, or penalty points for failing to disclose a driver’s identity UKPA to suggest that it has the authority to instigate a criminal prosecution based on a civil parking charge.
• UKPA is falsely implying legal consequences that do not exist, which is a clear breach of the Consumer Protection from Unfair Trading Regulations 2008 (CPUTR 2008), Schedule 1, Paragraph 7.
Annex H of the PPSCoP defines a Level 4 non-conformance as:
“Deliberate misrepresentation of authority.”
This is a serious breach of consumer protection laws and should result in suspension or expulsion from the ATA.
2. Breach of KADOE Contract – Report to DVLA
The DVLA’s Keeper at Date of Event (KADOE) contract requires parking operators to fully comply with the PPSCoP. As your rejection letter and Notice to Keeper fail to comply with multiple PPSCoP provisions, your continued access to DVLA keeper data is unlawful.
Annex H explicitly states that breaches affecting compliance with PoFA and the PPSCoP may warrant action against an operator’s ability to request registered keeper data.
This will be formally reported to the DVLA for investigation into the validity of your KADOE contract and potential suspension of access to registered keeper data.
3. Misleading and Prohibited Terminology – PPSCoP Level 3 Non-Conformance
Your appeal rejection letter contains misleading statements suggesting that:
• A court will assume the keeper was the driver unless they name the actual driver.
• Failure to provide a driver’s details could result in legal consequences that do not exist.
Annex H of the PPSCoP explicitly classifies as a Level 3 non-conformance:
“Using prohibited or misleading terminology on correspondence and communication sent to motorists.”
Such misleading statements misrepresent legal liability and violate consumer protection laws, requiring sanction points by the BPA.
4. PoFA 2012 Breaches – Invalid Keeper Liability (PPSCoP Level 2 Non-Conformance)
Your Notice to Keeper (NtK) fails to comply with Schedule 4 of the Protection of Freedoms Act 2012 (PoFA) in the following ways:
Breach of PoFA 9(2)(a) – Failure to Specify the "Period of Parking"
• PoFA requires the NtK to explicitly state the "period of parking".
• Your NtK only provides ANPR entry and exit timestamps, which do not equate to the actual "period of parking."
• It is not for the recipient to infer the duration—it must be clearly stated.
Breach of PoFA 9(2)(e)(i) – Failure to Provide Proper Invitation to the Keeper
• The NtK must invite the keeper to either pay the charge or provide the driver's details.
• Your notice fails to issue this invitation in the prescribed format, meaning it cannot lawfully transfer liability to the keeper.
Annex H of the PPSCoP lists PoFA non-conformance as a sanctionable offence:
• Level 1 Non-Conformance (2+ Sanction Points) – Sending a notice implying that they are pursuing the keeper using Schedule 4 of the Protection of Freedoms Act when they are outside of the timescales.
• Level 2 Non-Conformance (5+ Sanction Points) – Repeatedly sending parking charge notices implying that they are pursuing the keeper using Schedule 4 of PoFA when they are outside of the timescales.
Since your NtK fails fundamental PoFA requirements, UKPA is unlawfully pursuing keeper liability, in breach of the PPSCoP.
5. Procedural Misstatement of Appeal Deadline – PPSCoP Level 3 Non-Conformance
Your NtK incorrectly states that appeals must be received within 28 days of issue, rather than 28 days from receipt.
PPSCoP Section 8.1.2(e) states:
“The parking operator must ensure that a notice informs the recipient: that if the recipient appeals within 28 days of receiving the parking charge, the right to pay at the rate applicable when the appeal was made must stand for a further 14 days from the date they receive notification that their appeal has been rejected.”
Your misstatement of the appeal deadline misleads motorists into believing they have less time to appeal than they actually do, violating their consumer rights.
Annex H classifies this as a Level 3 non-conformance, warranting 9 sanction points.
Formal Complaint Resolution Required
I request the following actions from you:
A written response acknowledging and retracting the false statements in your appeal rejection letter.
Confirmation that you will cease issuing misleading threats regarding keeper liability and criminal prosecution in future correspondence.
An explanation of how you intend to correct the multiple PPSCoP and PoFA breaches identified in your NtK.
Confirmation that you have reviewed your processes to ensure full compliance with the PPSCoP and the KADOE contract.
Failure to properly address this complaint will result in:
• A formal complaint to the British Parking Association (BPA) requesting an investigation and sanctions.
• A formal complaint to the DVLA highlighting your breach of the KADOE contract.
• A referral to Trading Standards for misleading commercial practices.
I expect a full written response within 14 days. If you fail to respond satisfactorily, I will escalate this matter without further notice.
Yours sincerely,
[Your Name]
[Your Contact Details][/b]
PoFA 9(2)(e)(i) states:
9(1) A notice which is to be relied on as a notice to keeper for the purposes of paragraph 6(1)(b) is given in accordance with this paragraph if the following requirements are met.
(2) The notice
must—
(e) state that the creditor does not know both the name of the driver and a current address for service for the driver and invite the keeper—
(i) to pay the unpaid parking charges
Let's put that together:
The notice must state that the creditor does not know both the name of the driver and a current address for service for the driver and invite the keeper to pay the unpaid parking charges.
This is the reasoning that the NtK (the notice) is not FULLY compliant with ALL the requirements of PoFA.
This shows how it is argued:
Under Paragraph 9(2)(e)(i) of Schedule 4 of the Protection of Freedoms Act 2012 (PoFA), the Notice to Keeper (NtK) must include a specific invitation to the keeper to pay the charge. This requirement serves to ensure that the keeper understands their liability and has a clear course of action.
The operator cannot simply rely on the fact that the Parking Charge Notice (PCN) is addressed to the Keeper to satisfy Paragraph 9(2)(e)(i) of Schedule 4 of PoFA. The law explicitly requires a clear and specific invitation for the keeper to either:
• Pay the parking charge, or
• Provide the name and address of the driver (if the keeper was not the driver).
This is not an "implied" requirement; it must be explicitly stated. Merely inferring that the keeper is invited to pay because the notice is addressed to them does not meet the strict wording requirements of PoFA.
PoFA compliance requires specific wording. The law’s intention is to make the responsibilities of the Keeper clear and unambiguous. Phrases like "you are invited to pay this parking charge" or "you are required to do X, Y, Z" are examples of wording that PoFA expects.
If the notice only says, for example, "the Parking Charge is now payable" or "payment is required" without directly inviting the keeper to pay, this is insufficient under PoFA. The wording must link the keeper directly to the payment obligation in an unambiguous way.
The operator cannot claim keeper liability under PoFA if they fail to meet the explicit requirements of 9(2)(e)(i). This is a valid appeal (and defence) point, as courts and independent adjudicators should not rely on implied obligations instead of explicit compliance with statutory requirements.
Regarding the wording in PPSCoP section 8.1.2(e):
The parking operator must ensure that a notice informs the recipient: that if the recipient appeals within 28 days of receiving the parking charge, the right to pay at the rate applicable when the appeal was made must stand for a further 14 days from the date (subject to 8.1.2d) they receive notification that their appeal has been rejected
I then goes on to state in Note 2 to that section:
NOTE 2: A notice sent by post is to be presumed, unless the contrary is proved, to have
been delivered on the second working day after the day on which it is posted; and for this
purpose, “working day” means any day other than a Saturday, Sunday or a public holiday
in England and Wales.
We can take it that "delivered", "given" and "received" are the same thing.
The right to appeal is 28 days from receipt of the parking charge, not from the date of "issue" of the notice.
In your case, the notice was issued on Tuesday 14th January and it correctly states on the front that payment is to be made by Friday 14th February. However, look at the back of the NtK under "Appeals & transfer of liability". It incorrectly sates that all appeals must be received within 28 days of issue of the notice. That is clearly wrong.
This is a strong procedural point because it demonstrates non-compliance with the Private Parking Single Code of Practice (PPSCoP) section 8.1.2(e). The appeal deadline has been misstated, which is a clear breach of PPSCoP 8.1.2(e). This misleads the recipient into believing they have less time to appeal than they actually do, which is both procedurally unfair and legally significant in both a POPLA appeal and a potential court defence.
The PPSCoP is a binding requirement for British Parking Association (BPA) and International Parking Community (IPC) members. Any breach of the Code undermines the legitimacy of the parking charge and the operator’s compliance with regulations. Since the appeal timeframe is an important consumer right, a misstatement of it is a substantial flaw in the operator’s case.
I could go on, but you get the gist, hopefully.