You can use a single point POPLA appeal for this. Personally, I would send a snot-o-gram to the intellectually malnourished morons at GroupNexus as follows:
Dear GroupNexus,
Thank you for your generic rejection letter. I see that, once again, you have entirely side-stepped the single and fatal issue I raised.
Your Notice to Keeper does not comply with Schedule 4 of the Protection of Freedoms Act 2012. You chose not to issue a fully PoFA-compliant notice and it is now too late for you to do so. This means you cannot hold me, the registered keeper, liable for the charge.
You may shout about signage until you are blue in the face, but the law is quite clear: unless you comply with PoFA, only the driver can ever be liable. The driver has not been identified and will not be. Your entire position is therefore nothing more than a hollow attempt at extortion.
If you genuinely believe in your case, by all means waste your money at POPLA. My appeal will be very short: No keeper liability. Driver not identified. End of matter.
Please stop insulting my intelligence with boilerplate waffle about “BPA compliance.” The BPA Code of Practice does not override statute.
I await your operator response pack after I submit my POPLA appeal, so that I can again highlight your incompetence and inability to comprehend the law, assuming you do not concede at that point.
Yours sincerely,
[Name]
As for your POPA appeal, you only need to point out to the assessor two points why there can be no Keeper liability. You can use the following single point appeal:
PoFA says the notice must clearly tell me who the “creditor” is. That means the exact legal person who says I owe the money.
This notice uses the GroupNexus brand on top, but the small print says CP Plus Limited “trading as” GroupNexus. Those are not the same thing as one clear creditor. They are two different companies with different numbers at Companies House:
• GROUPNEXUS LIMITED — company no. 15560549 (incorporated 13 March 2024).
• CP PLUS LIMITED — company no. 02595379 (incorporated 26 March 1991).
By the date of the alleged event (shown on the NtK as 21/08/2025), GroupNexus Limited already existed as a separate legal entity. Saying “CP Plus Ltd t/a GroupNexus” does not identify whether the creditor is (a) CP Plus Limited, or (b) GroupNexus Limited, or (c) some brand name with no legal personality. PoFA requires one clear creditor, not a brand badge and a different company in the footer.
Because the notice does not identify the creditor as required by PoFA 9(2)(h), keeper liability cannot arise. The operator also still fails PoFA for:
• No PoFA invitation [9(2)(e)(i)] — it doesn’t state they don’t know the driver’s name/address for service and invite the keeper to pay or name the driver.
• No keeper-liability warning [9(2)(f)] — it doesn’t warn that after 28 days from the date the notice is 'given', if unpaid and they still don’t know the driver’s details, they have the right to recover the charge from the keeper.
In the simplest possible terms: the NtK must say exactly who wants the money and follow every PoFA rule. It doesn’t. The driver is not identified. So the keeper cannot be made to pay. The appeal must be allowed.
Assuming you are the registered keeper of the vehicle (you have the V5C in your name), then you can appeal with the below. As b789 notes, they have not complied with PoFA, so no keeper liability!
Dear Sirs,
I have received your Parking Charge Notice (Ref: ________) for vehicle registration mark ____ ___, in which you allege that the driver has incurred a parking charge. I note from your correspondence that you are not seeking to hold me liable as the registered keeper, under Schedule 4 of the Protection of Freedoms Act 2012 ("The Act"). You have chosen not to issue a Notice to Keeper in accordance with The Act, and it is now too late for you to do so.
There is no obligation for me to name the driver and I will not be doing so. I am therefore unable to help you further with this matter, and look forward to your confirmation that the charge has been cancelled. If you choose to decline this appeal, you must issue a POPLA code.
Yours,
If appealing online, be careful there are no drop down/tick boxes that cause you to identify who was driving, and keep a close eye on your spam folder for their response. If they do not respond within 28 days, chase them.