Free Traffic Legal Advice

Hi all,

I’m looking for advice on a private parking charge which started with Gemini Parking Solutions London Ltd, was then chased by Debt Recovery Plus, and is now being chased by Empira with a “pre-legal” style letter.

No County Court Claim Form has been received.

Important point: this is a leased vehicle. The registered keeper is the leasing company, not the individual receiving the later debt letters. The individual receiving the later letters is the hirer/lessee. The driver has not been identified and liability has not been admitted.

Key details
Parking operator/creditor on original PCN: Gemini Parking Solutions London Ltd
Location: GLL Waltham Forest Feel Good Centre, London E17 5AA
Alleged parking event date: 24/10/2024
Vehicle: leased vehicle
Registered keeper: leasing company
Individual receiving later correspondence: hirer/lessee
Driver has not been named
Liability has not been admitted
Amount now being chased: £170
No County Court Claim Form has been received
Original Gemini Parking Charge Notice

The original Parking Charge Notice was issued by Gemini Parking Solutions London Ltd and was addressed to the leasing company.

It states:

Date of issue: 06/11/2024
Alleged contravention: Failure to Pay for Duration of Stay
Entry time/date: 11:47:02 on 24/10/2024
Exit time/date: 13:27:11 on 24/10/2024
Location: GLL Waltham Forest Feel Good Centre
Original charge: £100, reduced to £60 if paid within 14 days
Payment evidence

There is a payment receipt showing:

Seller: Gemini Parking
Purchase date: 24/10/2024 at 12:49
Parking period: 12:45–13:45
Amount paid: £1.20
Location: GLL Feel Good Centre
Vehicle registration matches the vehicle

So payment was made and covered the vehicle until after the ANPR exit time of 13:27. However, Gemini appear to be alleging the full duration of stay was not paid for, because ANPR recorded entry at 11:47 and the paid session began at 12:45.

Hirer challenge to Gemini

The hirer challenged Gemini by email on 07/12/2024.

The email stated that the hirer:

was writing as the hirer of the vehicle;
formally disputed the charge;
denied any liability or contractual agreement;
did not admit who was driving;
stated that the Notice to Hirer failed to comply with POFA Schedule 4;
stated that the documents required under POFA Paragraph 14(2)(a) had not been supplied;
said the hirer could not be presumed to have been the driver.

A follow-up was sent on 08/12/2024 attaching a PDF version of the dispute letter.

Gemini response

Gemini responded around 10/12/2024.

Their response included this wording:

“Please be advised that this notice is not issued under POFA legislation and as a result the points mentioned in your email are not relevant in this case.”

They also said that notices are issued where terms and conditions are deemed breached, and that payment/validation data is processed through their payment match system. They said that at the final stage, registered keeper details are requested from the DVLA and a written notice is sent to the registered keeper giving an opportunity to appeal or transfer liability to the driver.

This appears important because Gemini seem to have confirmed they are not relying on POFA.

Hirer reply after Gemini said not POFA

The hirer replied again on 11/12/2024, pointing out that if Gemini are not relying on POFA, then they cannot hold the hirer liable simply because they are the hirer of the vehicle.

The hirer stated that any claim would need to rely on evidence of a personal contractual agreement with the hirer/driver, which was denied. The driver was still not identified.

Debt Recovery Plus stage

After this, the hirer/lessee received several Debt Recovery Plus letters. The ones available are dated:

07/01/2025
30/01/2025
14/02/2025
31/03/2025

These letters list the creditor as Gemini Parking Solutions London Ltd, location as GLL Waltham Forest Feel Good Centre, reason as Failure to Pay for Duration of Stay, and amount as £170.

Some of the wording says the recipient has not responded or has missed payment deadlines, but there had already been correspondence with Gemini in December 2024.

Empira stage

A later letter from Empira dated 05/05/2026 was received. This was headed “Formal Notice of Debt Recovery”.

This letter confusingly listed the client as:

APCOA Parking (UK) Limited

That is confusing because the original PCN and Debt Recovery Plus letters all identify Gemini Parking Solutions London Ltd as the operator/creditor.

A further Empira letter dated 01/07/2026 has now been received. This says:

“Pre Legal Instruction – Referral for Court Action”

It says the account is being prepared for referral to Gladstones Solicitors with a recommendation that legal proceedings be commenced.

This later Empira letter lists the client as:

Gemini Parking Solutions London Ltd

It also says it is issued in accordance with the Pre-Action Protocol for Debt Claims, but it does not appear to include a full Letter of Claim pack, Reply Form, Information Sheet, Financial Statement form, or supporting documents.

APCOA confusion

There is also some APCOA branding appearing in the background of the payment/communications process. The payment receipt screen shows APCOA/ScanPay branding, but the seller is shown as Gemini Parking. Some email responses also appear with APCOA branding, despite being from Gemini/Gemini-related addresses.

So the timeline appears to be:

Gemini original PCN → Gemini email exchange → Debt Recovery Plus → Empira, with some APCOA branding/inconsistency appearing along the way.

Main questions

1. Given Gemini stated the notice was not issued under POFA, and the driver has not been identified, can they pursue the hirer at all?
2. If Gemini are not relying on POFA, would they need to prove that the hirer was the driver or personally entered into the parking contract?
3. Does the fact this is a leased vehicle strengthen the position, given the registered keeper was the leasing company and the hirer has not admitted being the driver?
4. Was the hirer’s December 2024 response sufficient to put Gemini on notice that liability was denied and the driver was not being named?
5. Is the latest Empira letter a compliant Letter of Claim under the Pre-Action Protocol for Debt Claims, or is it still just a pre-legal/debt recovery letter?
6. Should the hirer now respond to Empira with a short “debt denied / refer back to Gemini / no POFA liability / no driver identified / provide documents” letter, or continue to wait unless an actual County Court Claim Form arrives?
7. Does the inconsistency between APCOA and Gemini matter, especially where one Empira letter names APCOA as the client but the PCN and later letters name Gemini?
8. On the parking facts, payment was made from 12:45 to 13:45 and the vehicle exited at 13:27, but ANPR entry was 11:47. Is there any realistic argument around payment/signage/grace periods, or is the stronger point simply that Gemini are not using POFA and have not identified the driver?
9. Should the hirer now request:
- the original Notice to Keeper sent to the leasing company;
- any Notice to Hirer;
- all documents used to transfer liability from the leasing company to the hirer;
- hire/lease documents they rely on;
- all ANPR images and payment records;
- signage from the date;
- landowner authority;
- breakdown of the £170;
- copies of all correspondence;
- confirmation of the legal basis for pursuing the hirer when they have stated the notice was not issued under POFA?

Any advice on the best next step and wording would be appreciated.

Redacted documents

Original Gemini PCN:



Payment receipt:



Latest Empira pre-legal letter dated 01/07/2026 — front:



Latest Empira pre-legal letter dated 01/07/2026 — back:



Empira formal debt recovery letter dated 05/05/2026 naming APCOA:



Example Debt Recovery Plus letter dated 31/03/2025:



I can also provide redacted screenshots of the Gemini email exchange if needed, including the response where Gemini stated that the notice was not issued under POFA.

So they say you can't appeal by email, then take up much of the email responding to your appeal - having their cake and eating it? 

You could leave it, having made your point. Or you could respond briefly as follows:

Dear Sirs,

I note the contents of your recent correspondence. I welcome your confirmation that you have chosen not to make use of POFA legislation and are therefore not seeking to hold me liable for this charge as the hirer of the vehicle.

As I now have written confirmation from you that you are unable to recover the charge from me, I see no need to appeal further, as we seem to be in agreement that I do not owe you anything as the hirer of the vehicle.

I trust this will be the end of the matter, however, any further attempts to hold me liable will be vigorously defended.

Yours faithfully,

Response-

'Thank you for contacting Gemini Parking Solutions


My apologies for the delay in responding to you.


As previously advised, please head to our website and submit an appeal, if no appeal or payment is made within the stipulated 28 days then this parking charge will be passed over to debt recovery 


Kind Regards,
Gemini Parking Solutions'

I read it as meaning they put the content that would otherwise have gone into the PDF into the body of their email. Would be useful for the OP to clarify.

Correct, content was sent in the body of the email instead of as an attachment within a pdf.

Attempting to appeal via Gemini website and the attached image is of the mandatory field that must be selected when appealing.

Is there an email I can appeal to?

[ Guests cannot view attachments ]

Yes, the lease company has the hirer’s current address and assume, has passed it on to Gemini. Additionally, the hirer was not the driver at the time of the incident.