If you want, the next sensible step is to tell A2Dominion in writing that they have failed to provide the promised update and that their failure is ongoing maladministration, and then lodge the Housing Ombudsman complaint immediately attaching A2D’s Stage 2 admission and the fact they still have not secured cancellation.
I suggest you respond to A2D with the following:QuoteDear Mr Tolhurst,
Thank you for your Stage 2 response and for partially upholding my complaint. I note the offer of £50 in recognition of your communication failures.
...............
Yours sincerely,
[Name]
Dear Mr Tolhurst,
Thank you for your Stage 2 response and for partially upholding my complaint. I note the offer of £50 in recognition of your communication failures.
However, I remain dissatisfied for the following reasons and do not regard the matter as resolved.
First, you have still not acknowledged that my tenancy has never been lawfully varied to impose a permit regime, visitor scratch cards, or any liability to a private parking company. A change of this nature requires proper consultation and a valid variation process compliant with landlord and tenant law and with clauses 9–11 of my tenancy. You have accepted that the introduction of enforcement was not properly communicated, which is effectively an admission that no lawful variation occurred.
Second, you have not accepted responsibility for the actions of the managing agent and its appointed parking contractor, whose enforcement regime is interfering with my tenancy rights. The introduction of a private enforcement scheme without a proper variation of the tenancy amounts to a derogation from grant and has resulted in repeated PCNs being issued in circumstances where my tenancy still gives me the right to use the estate without such obligations.
Third, the PCNs remain unresolved. Until they are cancelled and until you confirm that no further PCNs will be issued to residents in breach of existing tenancy rights, the issue remains live and the risk of further interference continues.
In light of the above, I cannot accept your position as the final resolution. I will therefore be referring this matter to the Housing Ombudsman for investigation into the service failures, the lack of lawful consultation or variation, and the ongoing impact on my tenancy rights.
Yours sincerely,
[Name]
The operator’s assertion that the freeholder’s “terms” can override tenancy rights demonstrates a fundamental misunderstanding of property and contract law. A tenancy is a legal estate in land that confers exclusive possession and associated rights, including parking rights where granted. Those rights cannot be unilaterally curtailed or substituted by third-party signage. Any attempt to do so without formal variation constitutes a derogation from grant. It is elementary law that a managing agent or contractor cannot confer upon itself greater rights than those held by its principal. Should the IAS choose to endorse such a plainly incorrect proposition, it would merely reinforce the widespread perception that this process is not an independent adjudication but a predetermined exercise in operator protection, confirming its reputation as a kangaroo court.
The operator’s supposed “evidence” is similarly defective. The claim that “the IPC hold a copy of the landowner agreement” carries no evidential weight when the document is withheld from the appellant. The operator must disclose an unredacted, contemporaneous, signed contract for this specific site showing its authority to issue and pursue PCNs; anything less defeats standing.
The photograph of an addressed envelope proves nothing regarding the alleged permit—there is no proof of contents, date, or service. A single image of a sign behind the vehicle is not proof of clear or readable terms, nor of contract formation. Likewise, the quoted “first and last observation times” do not constitute a statutory “period of parking” under PoFA and therefore cannot support keeper liability.
Finally, the claim that a resident has “ample opportunity to check signage” is irrelevant where tenancy rights take primacy. The operator’s entire case rests on the false premise that a third party can override a lawful tenancy through signage, a position that is untenable in law and unsupported by evidence.
They are trying to hold you liable for the charge, so "yes".Thank you!
Failure to comply with PoFA 2012 Sch 4 para 9(2)(a): The NtK does not “specify the period of parking”. Saying “The period of parking to which this notice relates is the period that immediately preceding the incident Date and Time” is not a period. As confirmed in Brennan v Premier Parking Solutions (2023), at least a short period of parking must be specified.
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. Primacy of tenancy and lack of consultation
TThe vehicle was parked on residential land where the keeper’s rights derive from a tenancy granted by A2Dominion South Limited. Under established principles of leasehold law, the tenancy agreement takes primacy over any subsequent arrangement made between the landlord and a third-party parking company.
The tenancy agreement contains no obligation to display a permit or visitor scratch card, and its terms permit parking subject only to avoiding obstruction or nuisance. Any previous display of a permit was done purely out of courtesy and not obligation.
Any attempt to impose new conditions through signage or private enforcement constitutes an unlawful variation of the tenancy and a derogation from grant, as it substantially interferes with rights already granted to the tenant. Accordingly, any agreement Parking & Property Management may hold with the landlord cannot override or diminish tenants’ contractual rights, and the operator therefore lacks standing to offer or enforce parking terms against residents or their visitors.
The operator is therefore put to strict proof of:• Written confirmation from the landowner that the operator’s permit scheme was lawfully introduced and binding on existing tenants; and
• Evidence that tenants received visitor permits prior to the date of the alleged contravention.
Without proof of these matters, the operator cannot claim that any contractual offer was capable of overriding the tenancy rights that take primacy over subsequently erected signage.2. 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.
3. 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.
4. 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.
5. 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.
6. 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.)
7. 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.
Subject: Stage 2 Complaint – Unlawful Variation of Tenancy Terms and Failure to Consult Regarding Parking Enforcement
Dear A2Dominion South Limited,
I am writing to escalate my complaint to Stage 2 of your complaints procedure. I remain dissatisfied with the Stage 1 response dated 15 October 2025 because it fails to address A2Dominion’s statutory and contractual duties under my tenancy agreement and common law.
Your Stage 1 response incorrectly claims that parking enforcement was introduced by the Managing Agents and therefore falls outside A2Dominion’s remit. This is factually and legally unsound. My tenancy is with A2Dominion South Limited, and clause (9) expressly obliges A2Dominion to consult tenants before any change in housing management or maintenance likely to have a substantial effect.
The introduction of third-party enforcement and a visitor-permit regime clearly constitutes such a change. Delegating the change to a Managing Agent does not relieve A2Dominion of responsibility for compliance with its own contract or the Tenant Involvement and Empowerment Standard.
Your reply also fails to show any evidence of the alleged consultation or the “letters” said to have been issued. No such letter was received by me or by other long-standing tenants in my block. If A2Dominion wishes to rely on this claim, please provide:• Copies of all correspondence and notices allegedly sent to residents concerning the introduction of Parking & Property Management’s enforcement scheme in 2022;
• The management or agency agreement authorising the Managing Agents to vary, amend, or restrict tenants’ parking rights;
• Confirmation of whether A2Dominion formally approved or ratified the scheme and, if so, the date of approval; and
• An explanation of why no consultation was carried out with affected tenants under clause (9).
Furthermore, clause (18) of my tenancy imposes no obligation to display permits or scratch cards. The unilateral introduction of such a requirement amounts to an unlawful variation of my tenancy and a derogation from grant.
Please therefore reconsider the matter and confirm that A2Dominion will:• Instruct Parking & Property Management to cancel the PCN issued against my vehicle;
• Cease or suspend enforcement in visitor bays pending proper consultation; and
• Ensure that any future changes to parking arrangements comply with the consultation and notification duties contained in clauses (9) – (11).
If this matter is not resolved at Stage 2, I will escalate it to the Housing Ombudsman for investigation into breaches of the Tenant Involvement and Empowerment Standard and maladministration in complaint handling.
Please acknowledge this Stage 2 escalation and provide a reference number.
Yours faithfully,
[Full Name]
[Flat / Building Address]
Subject: Formal Complaint – Parking & Property Management PCN / Unlawful Variation of Tenancy Terms
Subject: Residential Parking Issue – [Insert Property Address]
Subject: Residential Parking Issue – [Insert Property Address]
Dear [Managing Agent / Landlord Name],
I am writing in relation to a parking issue affecting my tenancy at [insert full address].
I am the tenant named in the lease and I understand that parking is managed at the property. I wish to confirm that a vehicle regularly parked at the premises—[insert make, model, and registration number]—is registered to my partner, who resides with me at the property.
This vehicle has been registered to this address and is used as part of our household. I would like confirmation that it is authorised to park in accordance with my tenancy rights, and I request that no enforcement action is taken against this vehicle.
Please confirm receipt of this letter and update your records accordingly.
Yours sincerely,
[Your Partner’s Full Name]
[Date]
I am the tenant and registered keeper at [full address].
Yes. Make a prompt, formal complaint to A2Dominion (the landlord) alongside the keeper-appeal already submitted.
Subject: Formal Complaint – Parking & Property Management PCN / Unlawful Variation of Tenancy Terms
Dear A2Dominion South Limited,
I am the tenant and registered keeper at [full address]. I am raising a formal complaint concerning a Parking Charge Notice (PCN) recently issued by Parking & Property Management for “not displaying a valid visitor scratch card permit” whilst parked in the car park serving my block.
I have lived here for 15 years. During this time, tenants of this block have always been permitted to park in visitor bays as well as lettered bays. No resident in this block has an allocated space. At no point have I ever been supplied with, or informed of, any requirement to obtain visitor scratch card permits.
Only recently, I noticed that new signs had been placed over the top of existing ones. This appears to be when Parking & Property Management began enforcing a permit regime. I did not receive any consultation, advance notice, or communication from A2Dominion about such changes.
This is contrary to my tenancy agreement, in particular:• Clause (9): A2Dominion must consult me before making changes in housing management or maintenance likely to have a substantial effect.
• Clause (10): I have a right to information about tenancy terms and A2Dominion’s repairing obligations, policies and procedures on tenant consultation, housing allocation and transfers, and performance as landlord.
• Clause (11): A2Dominion must establish a procedure for dealing with complaints and must inform tenants of any scheme changes.
• Clause (18): Roadways and parking restrictions are limited to obstruction, unroadworthy vehicles, and nuisance. There is no mention of a visitor permit scheme.
The introduction of a third-party enforcement regime without consultation amounts to a unilateral and unlawful variation of my tenancy and a derogation from grant.
I therefore require that A2Dominion:1. Immediately instruct Parking & Property Management to cancel this PCN and to cease enforcement against my vehicle and address.
2. Confirm that no lawful variation has been made to my tenancy requiring scratch card permits. If you believe there has been, provide copies of all tenant consultation records, communications, and policy documents.
3. Disclose the scope and authority of the landowner–operator agreement with Parking & Property Management.
4. Explain why no visitor permits have ever been supplied to me in 15 years of residence.
5. Confirm that no further PCNs will be issued against residents of this block without proper consultation and supply of permits.
Please treat this as a formal complaint under your complaints procedure. Kindly provide a written response, a complaint reference, and advise me which stage of your procedure this complaint is logged under. If unresolved, I will escalate to the Housing Ombudsman.
Yours faithfully,
[Full name]
[Flat and building address]
A single timestamp is not a "period"Their notice states just a single time. As Jfollows has also already said:
It’s the NTK that has to be compliant with PoFA 2012 on its ownThat additional information is available online does not remedy any failures on the issued notice. It would seemingly have been within their gift to list 04:45 - 04:55 as the period of parking on the notice (whilst that is not the total time the vehicle was parked, it would demonstrate a period of parking in excess of a relevant consideration period), but they chose not to do so.
The period of parking to which this notice relates is the period that immediately preceded the Incident Date and Time, the charge having been incurred for the reason as stated above
Is that the sum total of anything to do with parking mentioned in your lease?
the Notice to Keeper (NtK) is not PoFA compliant as it fails to mention the period of parking ads required by ¶9(2)(a). A single timestamp is not a "period"
I am the keeper of the vehicle and I dispute your 'parking charge'. I deny any liability or contractual agreement and I will be making a complaint about your predatory conduct to your client landowner.
As your Notice to Keeper (NtK) does not fully comply with ALL the requirements of PoFA 2012, you are unable to hold the keeper of the vehicle liable for the charge. Partial or even substantial compliance is not sufficient. There will be no admission as to who was driving and no inference or assumptions can be drawn. PPM 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. PPM have no hope should you try and litigate, so you are urged to save us both a complete waste of time and cancel the PCN.
Don’t obscure dates, please, as per https://www.ftla.uk/private-parking-tickets/read-this-first-private-parking-charges-forum-guide/