Appeal, this PCN is actually beatable at appeal, it genuinely isn't POFA compliant for once having been issued too late. Appeal along the lines of you are appealing as the keeper. You have no intention of naming the driver as there is no legal requirement to do so. As they do not know who the driver is and they issued the PCN outside of the 14 day period they cannot hold the keeper liable for the PCN under the protections of freedoms act 2012. As such they can not pursue you the keeper, and you expect them to cancel it. They might reject the appeal, as might IAS but you actually have strong defence grounds as long as you give them no indication who the driver was.