Free Traffic Legal Advice

No Clear Statement That They Are Relying on POFA
POFA Schedule 4, paragraph 9(2)(f) requires a specific statement:

“the creditor has the right to recover from the keeper so much of the unpaid parking charges as remain unpaid...”

APCOA’s PCN does not include this wording. Instead, it says:

“We invite you, the Registered Keeper, to pay...”

This wording is non-binding and fails to establish keeper liability under POFA.



also, No Mention of “Period of Parking”
POFA 9(2)(a) requires the PCN to “specify the period of parking to which the notice relates”.

Your PCN only gives entry and exit timestamps (ANPR capture). This refers to total time on site, not a clearly defined "period of parking".

POFA case law (such as POPLA appeals and ICO guidance) confirms that entry/exit times alone don’t satisfy the requirement for a defined parking period.


also2, Wording Implies Driver Liability Only
The “USEFUL INFORMATION” section says:

“As we do not know either the name of the driver or their current address, we invite you...”

And:

“Please note making payment... is accepting liability.”

This again undermines POFA compliance. Under POFA, if they wish to pursue the keeper, they must do so unambiguously and legally — not with invitations or requests.

also3, Lack of Mandatory POFA Warning About 28-Day Liability
POFA 9(2)(f) also mandates a warning that if the keeper does not provide driver details within 28 days, they may be held liable.

This PCN does not include that statutory warning.

Did the PCN Show Both Entry and Exit Times?

Under the BPA Code of Practice (para 21.5), if a Parking Charge Notice (PCN) is based on ANPR camera data, it must clearly show:

The full entry time

The full exit time

The duration of stay

AND…

Operators must not state or imply that the period of parking began at the point of vehicle entry, because that’s misleading. Parking starts when the driver finds a space and finishes when they leave it—not when passing a camera.

So the PCN must not just say “You were in the car park for 16 minutes”; it must show timestamped entry and exit photos.


If the PCN omits either time, Fails to show photos, or Misrepresents the duration as "time parked", That’s a breach of BPA Code of Practice, and a strong ground for POPLA appeal and court defence.