Hi,
I was wondering if I could have some advice please as I have made an appeal to the IAS after Euro parking rejected my appeal. I read through some comments on here so I used the following but I don't know if I've messed up. I have also receive the prima facie from the operator (below) claiming that the appellant was the drive but at no point has the drivers identity been revealed. I have until tomorrow to respond.
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.
However I didn't realise that this didn't go through to an Adjudicator and that EURO PARKING SERVICE were allowed to respond to this.
Their response was as follows
The operator made their Prima Facie Case on 21/05/2026 09:41:22.
The operator reported that...
The appellant was the driver.
The appellant was the keeper.
The operator is seeking keeper liability in accordance with PoFA..
ANPR/CCTV was used.
The Notice to Keeper was sent on 24/03/2026.
A response was received from the Notice to Keeper.
The ticket was issued on 21/03/2026.
The Notice to Keeper (ANPR) was sent in accordance with PoFA.
The charge is based in Contract.
The operator made the following comments...
There are multiple signages displayed on the site for the motorists to view and acknowledged the site regulations. (see evidence attached).As per the signages it is clearly mentioned that the motorist needs to enter the VRM into the kiosk while being in the car premises. (see evidence attached).The Landowner authority is not public information and this does not have to be disclosed.however, please be advised that all correspondence was issued in a timely manner. The IAS has access to this should the appeal go to this stage.The motorist has failed to comply with the site regulations during their stay in the car park. It is the sole responsibility of motorist to get their vehicle whitelisted so that it complies with the site regulations and which shall make it not liable for the Parking Charge notice. (see evidence attached)
Do I appeal to the Arbitration and do I use my initial appeal or something different. Sorry I'm panicking now
Any advice for be greatly appreciated. Thank you
