3. POPLA Appeal Advice – Civil Enforcement Ltd
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POPLA Appeal Advice – Civil Enforcement Ltd
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Hi all,

Date of incident: Monday, 7th July 2025
Charge amount: £100 (discounted to £60 initially – now expired)
Status: Initial appeal to CEL rejected – currently preparing POPLA appeal
POPLA code issued: Yes

PCN images: https://imgur.com/a/TjzQyyy

I'm looking for advice regarding a Parking Charge Notice issued by Civil Enforcement Ltd (CEL).

Background:

I attended the sports centre for a regular indoor football session (work group booking) and, as usual, went straight to reception to register my vehicle. On this occasion, I genuinely forgot to do so — an honest mistake on what was otherwise a normal visit.

I paid the £2.30 entrance fee on arrival, as I always do. I’ve attached a redacted screenshot of my bank statement to my POPLA appeal to prove I was a paying, legitimate user of the facility.

I've also contacted the sports centre manager to request they support the cancellation, either by confirming my attendance or contacting CEL directly.

My Appeal Argument So Far:

I was a genuine, paying customer using the facility as intended.

I have proof of payment, entry fee to the sports centre (bank statement).

My failure to register was an honest one-off oversight.

I have previously complied with the parking system at this site.

No financial loss occurred to the landowner or CEL.

The charge feels disproportionate given the circumstances.

What I’m Looking For:

Feedback on the strength of this POPLA appeal.

Any suggestions to improve the appeal wording or angle.

Advice on whether venue intervention can still help at this stage.

Anything else I might be overlooking.

Let me know if I should include the full appeal text here. Thanks in advance for any help!
« Last Edit: August 02, 2025, 05:34:25 pm by steve7765 »
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Re: POPLA Appeal Advice – Civil Enforcement Ltd
« Reply #1 on: »
You’ll be better advised to appeal on a technicality, for which we need to see the original PCN plus the exact text of the appeal you have already sent.
See https://www.ftla.uk/private-parking-tickets/read-this-first-private-parking-charges-forum-guide/

These companies do not have any compassion or interest in arguments about “genuine” mistakes. They couldn’t care less.

PS Do not obscure dates and times in anything you post here. They can be critical but some people seem to think that they need to be obscured.
« Last Edit: August 02, 2025, 05:30:08 pm by jfollows »
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Re: POPLA Appeal Advice – Civil Enforcement Ltd
« Reply #2 on: »
It’s a shame you didn’t come to this forum before you submitted your appeal. You’ve identified the driver. A non identified driver is a golden ticket to not paying a penny.

You’re going to need to post the full PCN front and back for us to see if there’s any additional arguments, such as non compliance.

I’m sure some people smarter than me will be along with additional advise I may have forgone shortly.


EDIT: It appears I was far too slow at typing my reply. Hopefully, the sports center direct them to cancel the invoice. Although, given they’ve now taken the time & effort to reject the appeal - if you can call reading and pressing a button time and effort - they may be minded to advice the sports center that they’ve spent “resources” on dealing with you and not cancel. Any excuse with these bottom feeders.
« Last Edit: August 02, 2025, 05:36:20 pm by beedmo »
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Re: POPLA Appeal Advice – Civil Enforcement Ltd
« Reply #3 on: »
Updated post with imgur link of PCN.
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Re: POPLA Appeal Advice – Civil Enforcement Ltd
« Reply #4 on: »
Indeed, if you identified the driver in your appeal then you may have metaphorically shot yourself in the footbat the same time, as @beedmo says, hence why we need more details in order to see if we can help you construct a defence.
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Re: POPLA Appeal Advice – Civil Enforcement Ltd
« Reply #5 on: »
Unfortunately I cannot find the exact wording of my initial appeal. I've logged onto the civil enforcement website and its not saved, and I didn't keep a word copy.

Attached is my appeal rejection.

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Re: POPLA Appeal Advice – Civil Enforcement Ltd
« Reply #6 on: »
The key point I made in my initial appeal was that I was a legitimate user of the sports centre on the 7th of July and I provided a screenshot of my bank statement to prove this.
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Re: POPLA Appeal Advice – Civil Enforcement Ltd
« Reply #7 on: »
Yep, standard boilerplate appeal rejection.

Now, you could make a Subject Access Request to receive the words you used in your appeal, however, that’ll take at least a month. Meaning your POPLA code will be null and void.

By your last message, it sounds like attaching a bank statement and using the phrasing “I” did this, you have identified yourself as driver.

Hopefully some of the regular posters will be along shortly to have a look at the detail of charge. Hopefully they can find some grounds for appeal.
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Re: POPLA Appeal Advice – Civil Enforcement Ltd
« Reply #8 on: »
I am thinking an outline of my appeal to POPLA could look like this.

I am the registered keeper of the vehicle in question and wish to appeal against the Parking Charge Notice issued by Civil Enforcement Ltd (CEL) on 7th July 2025. The PCN relates to a visit to a sports facility where I was a legitimate, paying customer attending a regular indoor football session through a workplace group booking. While I ordinarily comply fully with the parking procedures at this location, on this one occasion, I genuinely forgot to register my vehicle at reception. This was an honest oversight, not an attempt to avoid payment. I paid the required £2.30 entrance fee on arrival, as I always do. I have attached a redacted copy of my bank statement showing payment on that date as proof of my legitimate use of the facility.

I submit the following grounds of appeal:

1. No Evidence of Landowner Authority
CEL has not provided evidence that it has the legal authority to issue Parking Charge Notices and pursue payment at this site. As a third-party agent, CEL must demonstrate through a valid, contemporaneous contract that it has been authorised by the landowner (not merely a managing agent or site operator) to operate and enforce parking terms on this land. The BPA Code of Practice (Section 7.1) requires this. CEL is put to strict proof that such a contract exists and that it specifically authorises CEL to issue charges in its own name at this site. If such evidence cannot be produced, CEL has no standing to pursue this charge and the appeal must be upheld.

2. Inadequate Signage – BPA Code of Practice Breach
While I am familiar with the process of registering my vehicle at this facility, the signage on-site failed to provide adequate reminders or prompts at the point of arrival or within the reception area to alert users to this obligation. For regular users, especially those engaged in habitual routines, signage must be clear and placed strategically to prompt compliance every time. The signs failed to act as a sufficient reminder in this case. The BPA Code of Practice (Section 19) requires signage to be both clear and prominently placed. On this occasion, I simply forgot to register — a situation that more prominent or clearer reminders (e.g., at eye level or in the reception area itself) could have prevented. Therefore, I ask that the signage’s sufficiency and prominence be properly reviewed.

3. No Grace Period Applied – BPA Code of Practice Clause 13
According to Clause 13 of the BPA Code of Practice, operators are required to allow a reasonable grace period before issuing a charge. This period is intended to allow drivers sufficient time to read signage and comply with parking conditions. In this case, no grace period was observed. As a paying customer who went directly into the facility and would ordinarily register the vehicle on arrival, I should have been given a reasonable amount of time to register the vehicle or rectify the oversight. Issuing a PCN without allowing for any grace period demonstrates non-compliance with the Code and is grounds for cancellation.

4. The Charge is Not a Genuine Pre-Estimate of Loss and Is a Penalty
The £100 charge is not a genuine pre-estimate of loss. CEL has suffered no loss whatsoever as a result of my failure to register on this single occasion. I paid to use the facility, just as any other guest would. There was no unauthorised parking, overstay, or misuse of the premises. The charge is therefore punitive, not compensatory. The landmark case ParkingEye v Beavis is not applicable here. That case involved a retail park with free parking where the charge was justified as a deterrent. In contrast, this site is a paid-access facility. There is no reasonable commercial justification for such a high charge under these specific circumstances. The charge in this context functions purely as a penalty and should be deemed unenforceable under contract law.

5. I Was a Legitimate, Paying Customer
I was a valid user of the facility, having paid the entry fee in full on the date in question. I have provided a redacted bank statement as proof of payment. I regularly use this site and have always registered my vehicle as required. This was a one-off error made in good faith, with no intent to breach any terms or to deprive CEL or the landowner of any income. The operator suffered no financial loss. POPLA should consider this in determining whether the imposition of a £100 charge is fair, reasonable, and proportionate in the circumstances. The operator has failed to consider mitigating factors, which is contrary to the principles of natural justice and the guidance contained in the BPA Code of Practice.

6. CEL’s Evidence Must Be Scrutinised for Accuracy and Timeliness
Should CEL submit evidence to POPLA, I request that POPLA carefully scrutinise any documents for authenticity, relevance, and timeliness. Any evidence submitted after the operator’s deadline should be disregarded in line with POPLA’s procedural rules. CEL has a history of relying on generic or templated witness statements, which do not meet the required standard of proof. I reserve the right to respond to CEL’s evidence if and when it is shared with me.

Conclusion
In summary, this PCN has been issued in contravention of multiple sections of the BPA Code of Practice. CEL has failed to demonstrate that it has landowner authority, has failed to apply the mandatory grace period, and relies on inadequate signage to impose disproportionately high charges. I was a genuine customer who made an honest mistake, caused no loss, and complied in every other respect with the parking terms on all previous visits. For these reasons, I respectfully request that POPLA uphold my appeal and cancel the Parking Charge Notice.

Thank you for your consideration.
« Last Edit: August 02, 2025, 07:34:40 pm by steve7765 »
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Re: POPLA Appeal Advice – Civil Enforcement Ltd
« Reply #9 on: »
The Notice to Keeper (NtK) is PoFA compliant so all the wiffle-waffle about not identifying the driver is irrelevant because they don't have to. The Keeper is liable if the driver is not identified.

As for the POPLA appeal, you have about as much chance as a snowball in hell for that succeeding. Forget anything about mitigation. POPLA will not consider it. They will only consider the PPSCoP and the law. You have already admitted that you did not comply with the terms and conditions and are therefore in breach of contract.

If you are going to go through the motions, I would have suggested to at least concentrate on things such as poor signage, but you've already admitted that you know you breached the terms, so you can't use that argument. You can put the operator to strict proof that they hold a valid contract flowing from the landowner to operate at the location.

Otherwise, I would advise you press on the Sports Facility management to call their dogs off. If they are the party that has contracted CEL and they try to fob you off with the oft heard "Nothing we can do about it, you must appeal to the operator", then ask them who is the Monkey and who is the Organ Grinder in their contractual relationship with CEL.

Without ruching to send your POPLA appeal as you have 33 days from the date of the appeal rejection to actually submit it, I would also advise that you consider whether this may be a lost cause and you consider taking the mugs discount.
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Never argue with stupid people. They will drag you down to their level and then beat you with experience” - Mark Twain
Re: POPLA Appeal Advice – Civil Enforcement Ltd
« Reply #10 on: »
If I contact management and they confirm I was there should I appeal to POPLA or should they cancel the PCN directly? They have told me before there is nothing they can do and gave me a template to appeal with. (not what I have put below).

I am appealing against the Parking Charge Notice issued by Civil Enforcement Ltd (CEL) on the grounds that CEL has not demonstrated landowner authority to operate on the site in question.

1. No Evidence of Landowner Authority
I require Civil Enforcement Ltd to provide strict proof that it has current, valid, and written authorisation from the landowner (not merely a managing agent) to issue Parking Charge Notices at the location stated on the PCN.

This must include the following:

The full, signed contract between CEL and the landowner (not a site manager or agent).

The contract must show that CEL is authorised to operate, manage parking, and pursue charges in its own name.

The contract must be valid on the date of the alleged contravention (7th July 2025).

The BPA Code of Practice (Section 7.1) makes it clear that operators must have such authority and produce it on demand to establish their legal standing.

If CEL fails to provide this unredacted evidence, POPLA must uphold the appeal. Any undated or unsigned documents, heavily redacted witness statements, or generic templates should not be accepted as valid proof.
« Last Edit: August 02, 2025, 08:36:13 pm by steve7765 »
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Re: POPLA Appeal Advice – Civil Enforcement Ltd
« Reply #11 on: »
You have 28 days to submit to POPLA so let's work on it a little. With POPLA, you have one chance to submit your case and once its submitted, no further evidence may be submitted. I'd also wait until you hear back from the gym managers before submitting. If the operator put someone to work on creating an evidence rebuttal package, they're going to use the fact that they've put money into the proccess to attempt to recover the invoice they've issued - lets not hand them to much ammunition.

That being said, lets go point by point;

Your Introduction
I'd keep the first two sentences. Bin the rest of it. These companies are not known for their use of discretion - they're whole bussiness comes from people paying their invoices! If you hand to them evidence that you knew the proccess, they're going to use it.

1. No Evidence of Landowner Authority
Yep, fair enough. Be prepared for them to supply the contract when they provide their evidence.

2. Inadequate Signage – BPA Code of Practice Breach
I'd take out the bit where you admit to knowing the process for the reasons I've already outlined. I've had a look on google street view and there does appear to be a sign at the entrance, however, it appears it can only be seen if you enter the car park traveling northbound on Maidstone Rd - bare in mind, I'm going on images from 09/24, If you could supply photos of up to date signage with timestamps (using an app such as timemark) this may assist us and your case.

You could add a quote from the BPA code of practice - Clearly a breach if you can only see from one direction.

Quote
The size and positioning of the sign must take into account the expected speed and direction of travel of vehicles approaching the entrance and must be visible
(i.e. not be obscured e.g. by foliage or other objects).

3. No Grace Period Applied – BPA Code of Practice Clause 13
I'm not sure this is relevant really. Generally by grace period, they mean 10 mins. This is to come in and decide if you want to accept the terms.

4. The Charge is Not a Genuine Pre-Estimate of Loss and Is a Penalty
They'll attempt to rebutt this but I don't think it's harmful to keep it in

5. I Was a Legitimate, Paying Customer
Again, I think it'd be better to remove traces that you're aware of the process.

6. CEL’s Evidence Must Be Scrutinised for Accuracy and Timeliness
I'm not sure if this is relevant. This is how POPLA works. The operator sees your evidence and responds with theirs. Even though the the assesors are supposed to be independent, I wouldn't want to taint their view of the case.

This is only how I see it and I welcome anyone else to put their opinion forward.
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Re: POPLA Appeal Advice – Civil Enforcement Ltd
« Reply #12 on: »
The POPLA code is valid for 28 days, after service of 5 days. So, it is valid for 33 days from the date of the initial rejection. This is not a guess but based actual fact.

GPEOL is not longer even considered. A "grace period" is different and separate from a "consideration period". Please get any use of these definitions correct if you are going to use them. How on earth does a "grace period" apply to a stay of 1:55 when the alleged contravention is "Payment not made/Permit not obtained in accordance with notified terms"?

There is no longer a "BPA Code of Practice", unless you are referring to signage. All other references since October last year are not to the BPA/IPC Private Parking Single Code of Practice (PPSCoP).
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Never argue with stupid people. They will drag you down to their level and then beat you with experience” - Mark Twain
Re: POPLA Appeal Advice – Civil Enforcement Ltd
« Reply #13 on: »
Thanks for your replies.

Since I mentioned the mistake of not registering the car in my appeal to CEL, if CEL provides this to POPLA they will just view this this as a breach of contract. Thank you for pointing out that they don't consider mitigating excuses like honest mistakes. The only option I have to appeal this is to challenge whether CEL has legal authority - i.e., that they hold a valid, unredacted contract from the owner authorising them  to issue PCNs on this site.

But I think that is unlikely to succeed. Between 1 October 2021 to 30 September 2022, POPLA decided in favour of  Civil
Enforcement Limited and upheld the validity of the PCN in 83% of contested cases, and I don't have any other evidential points in my appeal.

I've previously contacted the management at the site and they will not contact CEL to cancel it either.

If my appeal is rejected I void the discounted mug charge of £20 and it goes up to £100.

So best option is I accept I'm in a losing battle here and pay the £20?
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Re: POPLA Appeal Advice – Civil Enforcement Ltd
« Reply #14 on: »
Are you asking us or telling us?

Quote from: steve7765 on August 03, 2025, 01:23:22 pm
But I think that is unlikely to succeed. Between 1 October 2021 to 30 September 2022, POPLA decided in favour of  Civil
Enforcement Limited and upheld the validity of the PCN in 83% of contested cases, and I don't have any other evidential points in my appeal.

Where are you getting that statistic from? It sounds very much like something CEL have put into one of their letters in the hope you are low-hanging fruit on the gullible tree.

You have to face the fact that you made a mistake by not registering your vehicle this time. You knew about the requirement to register it. You therefore breached the terms and conditions of parking at that location and the driver became liable for the charge.

If the management of the sports centre do not care about your custom, then take your business elsewhere and let them know why. They are able to get it cancelled but can't be othered. So why should you.

You can try and fight this but you have already shot yourself in the foot by identifying the driver. You have very little hope of winning a POPLA appeal.

SO, if you've been offered a settlement of £20, I would think that is your best bet and learn a lesson for the next time you have to interact with an unregulated private parking company. If you wanted to fight it, you have a much less than 50% of winning, so cut your losses.
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