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I have just looked through and found this, again by AI:

Comments on Operator Evidence Pack – PCN Reference: [XXXX]

I have reviewed the operator’s evidence, including their assertion that they do not need to quote the legal schedule verbatim.
The operator’s Notice to Keeper states:
"you are advised that if after the period of 30 days beginning with the day after that on which this parking charge notice to keeper is given..."
This does not comply with the mandatory requirements of Schedule 4, paragraph 9(2)(f) of the Protection of Freedoms Act 2012. The Act requires a specific warning using 28 days, not 30 days.
By altering this prescribed element, the operator has failed to meet the strict conditions for keeper liability. No such liability arises. They may only pursue the driver (whose identity they do not know). I therefore request that the appeal be allowed and the charge cancelled on this basis.


Is this a strong argument? I mean surely they have to fully comply with the legal guidlines?

There were mitigating factors which i am sure they wont pay attention to. The driver is a Mental Health Nurse visiting a client and the appointment over ran. They have the parking app as they use it all the time and paid (or least they thought)as usual for the extra hour. It wasnt until a week or so later they realised the payment didn't go through, by which time it was too late to pay (no history on the app at all for this payment).

I can't add on any new evidence anyway that didn't make up my first appeal, so I think the above is my best chance.

Hoping others can chime in with experiences that may help on this instance.

Ok. So I have gone back through my initial response, made some tweets to it. I think this is a stronger arguement

I have reviewed the operator’s evidence and case summary. I maintain my appeal and request that it be allowed for the reasons below. The operator has failed to establish keeper liability and has not proved the contravention adequately.

1. The Notice to Keeper (NTK) is not compliant with Schedule 4 of the Protection of Freedoms Act 2012 – No Keeper Liability

This is my primary ground of appeal. The operator relies on keeper liability but their NTK fails to meet the mandatory statutory requirements of paragraph 9(2) of Schedule 4 POFA 2012.

The operator’s NTK states:

"you are advised that if after the period of 30 days beginning with the day after that on which this parking charge notice to keeper is given..."

This wording is materially defective because paragraph 9(2)(f) requires the NTK to warn the keeper that the creditor will have the right to recover the unpaid parking charge from the keeper after the period of 28 days beginning with the day after the notice is given (subject to the other conditions).

The operator has substituted 30 days for the statutory 28 days. This is not a minor or inconsequential change. It misleads the keeper as to the precise legal trigger for liability and alters the timing Parliament prescribed.

The operator claims “nothing in Schedule 4 requires us to quote it verbatim” and that the BPA has “approved” their wording. This is misleading. While the entire Schedule need not be reproduced, the Act does mandate that specific prescribed information (including the exact 28-day warning in 9(2)(f)) must be included. BPA approval does not override statute or bind POPLA. Adjudicators assess compliance with the law, not trade body approval.

By failing to convey the mandatory warning accurately, the operator has not satisfied the strict conditions in paragraph 9. Therefore, the conditions for keeper liability under paragraph 6(1)(b) are not met. They have no legal basis to pursue me as the registered keeper. Liability (if any) remains with the unknown driver.

2. No admission as to who was driving

I appealed strictly as the registered keeper. I have never admitted to being the driver, and the operator has provided no evidence identifying me as the driver on 11 March 2026. Without a compliant NTK under POFA, they cannot pursue the keeper.

The operator has provided a redacted landowner agreement and details of parking sessions. This does not cure the fundamental failure on POFA compliance. The fact that no payment was recorded does not prove the contravention if the driver was not adequately informed of the terms.

For the reasons above — particularly the clear defect in the NTK — I respectfully ask POPLA to allow the appeal and cancel the charge in full.

Opinions?