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3. Post the notice(s) you have received – as well as providing important context, the notices may contain/omit details that can be used to help you successfully fight the charge. Upload photos of any and all notices you have received from the parking company. You should show us all pages of the notice(s), remove personal details (name/address, PCN reference number, Vehicle Registration Mark), but show us all dates and times. Details that you think are trivial could help you win, so don’t leave anything out.

Dear Sir or Madam,

Re: Parking Charge Notice [PCN reference] – Vehicle [VRM]

Your letter dated 18 November 2025

I write as the registered keeper.

Your response fails to deal with the central point raised in my appeal, namely that your Notice to Keeper (“NtK”) is not compliant with Schedule 4 to the Protection of Freedoms Act 2012 (“PoFA”), specifically paragraph 9(2)(e)(i). As such, you cannot rely on PoFA to transfer liability from the unknown driver to me as keeper.

PoFA 9(2)(e)(i) argument
Schedule 4 paragraph 9(2) is binary (“must” means all or nothing) and this NtK omits the mandatory invitation to the keeper to pay under 9(2)(e)(i).
Schedule 4 paragraph 9(2) does not say the notice should include certain things. It says:

“The notice must — (a)… (b)… (c)… (d)… (e)… (f)… (g)… (h)… (i)…”.

“Must” is compulsory. PoFA 9(2) is a statutory gateway to keeper liability: either every required element is present or the gateway never opens. There is no such thing as “partial” or even “substantial compliance” with 9(2). Like pregnancy, it is binary: a notice is either PoFA-compliant or it is not. If one required limb is missing, the operator cannot use PoFA to pursue the keeper. End of.

Here the missing limb is 9(2)(e)(i). That sub-paragraph requires the NtK to invite the keeper to pay the unpaid parking charges. The law is explicit that the invitation must be directed to “the keeper”. It is not enough to tell “the driver” to pay; it must invite “the keeper” to pay if the creditor wants keeper liability.

What this NtK actually does is talk only to “the driver” when demanding payment, and nowhere invites “the keeper” to pay. The demand section of the NtK is framed entirely in driver terms (e.g. “the driver is required to pay within 28 days” / “payment is due from the driver”) and there is no sentence that invites “the keeper” to pay the unpaid parking charges. The word “keeper” (if used at all) appears only in neutral data/disclosure paragraphs or generic definitions, not in any invitation to pay. That omission is precisely what 9(2)(e)(i) forbids.

For the avoidance of doubt, 9(2)(e) contains two limbs:

1. 9(2)(e)(i) – an invitation to the keeper to pay; and
2. 9(2)(e)(ii) – an invitation either to name and provide a serviceable address for the driver and to pass the notice to them.

Even setting aside 9(2)(e)(ii), the absence of the 9(2)(e)(i) keeper-payment invitation alone is fatal to PoFA compliance. The statute makes keeper liability contingent on strict satisfaction of every “must” in 9(2). Where a notice invites only “the driver” to pay, it fails 9(2)(e)(i), so it is not a PoFA notice. The operator therefore cannot transfer liability from an unidentified driver to the registered keeper. Only the driver could ever be liable; the driver is not identified. The keeper is not liable in law.

No duty to name the driver
Your latest letter misrepresents PoFA by suggesting that I “should” provide the driver’s name and address and that, if I do not, you will have “the right to recover” the charge from me under paragraph 9(2)(f).

PoFA imposes no obligation on a registered keeper to name the driver. It merely sets out conditions that must be met if an operator wishes to hold the keeper liable. Because your NtK fails 9(2)(e)(i), those conditions have not been met. The necessary gateway to keeper liability remains closed.

For the avoidance of doubt:
indent]1. I will not be identifying the driver;
2. You cannot lawfully rely on PoFA to pursue me as keeper; and
3. Any attempt to do so will be defended, starting from your non-compliance with 9(2)(e)(i).[/indent]

Subsequent letters cannot cure a defective NtK
Keeper liability, if it arises at all, must arise from a fully compliant NtK. You cannot retrospectively “repair” a defective NtK by quoting PoFA 9(2)(b) or 9(2)(f) in a later letter. The fact remains that the NtK itself fails to satisfy 9(2)(e)(i), and that is determinative.

Put up or shut up
Given the above, you now have only two reasonable options:

1. Cancel this Parking Charge Notice; or
2. Issue a formal rejection of my appeal, accompanied by a POPLA verification code, so that an independent assessor can consider, as a preliminary issue, your failure to comply with PoFA 9(2)(e)(i) and the consequent absence of keeper liability.

Any further template letters pressing me, as keeper, to either pay or to name the driver – without addressing your lack of compliance with 9(2)(e)(i) – will be treated as unreasonable and may be relied upon in any complaint to your principal and relevant bodies.

I look forward to either written confirmation that the charge has been cancelled or, failing that, your rejection and POPLA code.

Yours faithfully,

[Name]
Registered Keeper