I am submitting a complaint under the DMCC Act 2024 about structural unfairness and consumer harm in the private parking appeals system run by the International Parking Community (IPC) and the Independent Appeals Service (IAS).
Both the IPC and IAS are owned and operated by the same private company, United Trade and Industry Ltd. The trade association representing parking operators and the “independent” appeals body sit under one corporate owner. This is a direct, embedded conflict of interest: the body that sets rules for operators also controls the appeals outcome on those operators’ tickets.
In 2023/24, IPC members issued around 2.8 million private parking charge notices (PCNs). A motorist must first appeal to the operator; if refused, they may escalate to the IAS. The IAS upholds fewer than 5% of appeals. Motorists are rarely successful. The process is opaque, lacks transparency, and offers no meaningful route to challenge outcomes. There is no independent oversight or external accountability.
The IAS claims its adjudicators are legally trained (solicitor or barrister level), yet adjudicators are anonymous. Consumers cannot verify qualifications or professional standing. Anonymity undermines transparency and accountability. The IAS cites a retired barrister on its board, which does not prove individual adjudicators are legally qualified. Anonymous decisions purporting to rely on legal training are impossible to verify, and many decisions show weak legal reasoning, making the qualifications claim misleading.
These practices deceive consumers. Anonymous “legally trained” decisions lead motorists to believe they have no further recourse except to pay or instruct a solicitor. In reality, the IAS is not a statutory tribunal, adjudicators are not publicly accountable, and decisions have no binding legal authority. Consumers are misled into thinking they have exhausted their rights when they have been denied independent redress.
By contrast, the British Parking Association outsources its second‑stage appeals to POPLA, which is structurally separate and upholds about 38% of appeals. The IPC/IAS model lacks any separation because both are owned by United Trade and Industry Ltd. This single‑owner structure is uniquely conflicted and amplifies consumer harm.
I am not the direct recipient of any PCN or IAS decision. I act as an independent advisor to motorists. I run gullibletree.com, where motorists report PCNs, and I advise daily on the Free Traffic Legal Advice forum (FTLA.uk), assisting on hundreds of cases. My evidence is anonymised but includes narratives and case histories showing consistent patterns of unfairness across operators and sites.
This setup causes systemic consumer harm: denial of fair redress, an appeals process structurally biased by single‑owner conflict of interest, an implausibly low uphold rate, anonymity and unverifiable qualifications that mislead consumers, and a lack of independent oversight.
I request that the CMA investigate United Trade and Industry Ltd under the DMCC for operating a structurally unfair, deceptive appeals system that denies consumers meaningful redress and misleads them into believing they have no further rights.
I can provide further evidence on request, including proof of added consumer frustration caused by the IAS webform, which blocks copy‑paste and forces motorists to type long responses manually instead of using prepared texts.
We operate some "house rules" on the site.Please start your own thread.
1. We operate a "one case, one thread" rule. This means that you should keep any posts relating to one case (one incident of speeding, one PCN, etc) to a single thread. Do not start multiple topics on the same case.
If the IAS assessor is legally trained (questionable), they would know liability is the threshold issue: this is railway land governed by byelaws, not “relevant land” under PoFA, the driver is unidentified, and the operator expressly disavows PoFA, therefore there is no lawful route to hold the Keeper liable and the enquiry ends there.
Any attempt to conjure liability by asserting that the Keeper was “probably” the driver is a legal fiction flatly contrary to the very purpose of PoFA (which was enacted to remove such inferences), repeatedly rejected in persuasive authorities including VCS v Edward (2023) and the consistent line of county court appeal decisions disapproving Elliott v Loake/AJH Films misuse, and it would be irrational and perverse to proceed to signage or “no stopping” merits when the claimant has no cause of action against the Keeper at all.
If the anonymous IAS “assessor” were genuinely legally trained, never mind the solicitor or barrister they pretend to be, they would recognise that liability must first exist before any alleged contractual breach can even be discussed. The operator admits PoFA does not apply, as this is alleged contravention was at a railway station and therefore not relevant land.
Without PoFA and without an identified driver, there is simply no lawful route to Keeper liability. To fabricate liability “on the balance of probabilities” is not only contrary to statute but flies in the face of persuasive case law such as VCS v Edward (2023), where the court confirmed that no such presumption exists. The whole point of PoFA was to prevent precisely this kind of inference.
To proceed on that basis would expose the IAS’s assessment process as legally incompetent at best, and institutionally dishonest at worst — a parody of legal reasoning conducted by anonymous baristas masquerading as barristers.
The operator may instead pursue the keeper on the balance of probabilities if no driver is named, a position that has been upheld in numerous appeal casesis a lie.
You should send the following as your IAS appeal. Not much chance of that being successful either, but worth a try and it will cost them to challenges it unless they concede.
I am the registered keeper of the vehicle. I deny any liability for this parking charge and appeal in full.
The parking operator bears the burden of proof. It must establish that a contravention occurred, that a valid contract was formed between the operator and the driver, and that it has lawful authority to operate and issue Parking Charge Notices (PCNs) in its own name. I therefore require the operator to provide the following:1. Strict proof of clear, prominent, and adequate signage that was in place on the date in question, at the exact location of the alleged contravention. This must include a detailed site plan showing the placement of each sign and legible images of the signs in situ. The operator must demonstrate that signage was visible, legible, and compliant with the IPC Code of Practice that was valid at the time of the alleged contravention, including requirements relating to font size, positioning, and the communication of key terms.
2. Strict proof of a valid, contemporaneous contract or lease flowing from the landowner that authorises the operator to manage parking, issue PCNs, and pursue legal action in its own name. I refer the operator and the IAS assessor to Section 14 of the PPSCoP (Relationship with Landowner), which clearly sets out mandatory minimum requirements that must be evidenced before any parking charge may be issued on controlled land.
In particular, Section 14.1(a)–(j) requires the operator to have in place written confirmation from the landowner which includes:• the identity of the landowner,
• a boundary map of the land to be managed,
• applicable byelaws,
• the duration and scope of authority granted,
• detailed parking terms and conditions including any specific permissions or exemptions,
• the means of issuing PCNs,
• responsibility for obtaining planning and advertising consents,
• and the operator’s obligations and appeal procedure under the Code.
These requirements are not optional. They are a condition precedent to issuing a PCN and bringing any associated action. Accordingly, I put the operator to strict proof of compliance with the entirety of Section 14 of the PPSCoP. Any document that contains redactions must not obscure the above conditions. The document must also be dated and signed by identifiable persons, with evidence of their authority to act on behalf of the parties to the agreement. The operator must provide an agreement showing clear authorisation from the landowner for this specific site.
3. Strict proof that the enforcement mechanism (e.g. ANPR or manual patrol) is reliable, synchronised, maintained, and calibrated regularly. The operator must prove the vehicle was present for the full duration alleged and not simply momentarily on site, potentially within a permitted consideration or grace period as defined by the PPSCoP.
4. Strict proof that the Notice to Keeper complies with the Protection of Freedoms Act 2012 (PoFA), if the operator is attempting to rely on keeper liability. Any failure to comply with the mandatory wording or timelines in Schedule 4 of PoFA renders keeper liability unenforceable.
5. Strict proof that the NtK was posted in time for it to have been given within the relevant period. The PPSCoP section 8.1.2(d) Note 2 requires that the operator must retain a record of the date of posting of a notice, not simply of that notice having been generated (e.g. the date that any third-party Mail Consolidator actually put it in the postal system.)
6. The IAS claims that its assessors are “qualified solicitors or barristers.” Yet there is no way to verify this. Decisions are unsigned, anonymised, and unpublished. There is no transparency, no register of assessors, and no way for a motorist to assess the legal credibility of the individual supposedly adjudicating their appeal. If the person reading this really is legally qualified, they will know that without strict proof of landowner authority (VCS v HMRC [2013] EWCA Civ 186), no claim can succeed. They will also know that clear and prominent signage is a prerequisite for contract formation (ParkingEye v Beavis [2015] UKSC 67), and that keeper liability under PoFA is only available where strict statutory conditions are met.
If the assessor chooses to overlook these legal requirements and accept vague assertions or redacted documents from the operator, that will speak for itself—and lend further weight to the growing concern that this appeals service is neither independent nor genuinely legally qualified.
In short, I dispute this charge in its entirety and require full evidence of compliance with the law, industry codes of practice, and basic contractual principles.
Thank you, I will appeal with that template
Please be warned: that if, after the period of 28 days beginning with the day after that on which the Notice is given (i) the amount of the unpaid Parking Charge specified in this Notice has not been paid in full, and (i) we do not know both the name of the driver and a current address for service for the driver, we may recover from you, the keeper, on the assumption that you were the driver, so much of that Parking Charge as remains unpaid.
I am the registered keeper. UKCPS cannot hold a registered keeper liable for any alleged contravention on land that is under statutory control. As a matter of fact and law, UKCPS will be well aware that they cannot use the PoFA provisions because Leeds City Stattion is not 'relevant land'.
If the landowner wanted to hold owners or keepers liable under Railway Bylaws, that would be within the landowner's gift and another matter entirely. However, not only is that not pleaded, it is also not legally possible because UKCPS is not the station owner and your 'parking charge' is not and never attempts to be a penalty. It is created for UKCPS’s own profit (as opposed to a bylaws penalty that goes to the public purse) and UKCPS has relied on contract law allegations of breach against the driver only.
The registered keeper cannot be presumed or inferred to have been the driver, nor pursued under some twisted interpretation of the law of agency. Your NtK can only hold the driver liable. UKCPS have no hope should you be so stupid as to litigate, so you are urged to save us both a complete waste of time and cancel the PCN.