Links to docs/sign post images:
https://ibb.co/m5gTM8kdhttps://ibb.co/RGzgS9VZhttps://ibb.co/1h1XX54https://ibb.co/Nn3J5vKZHi all,
I would appreciate some experienced eyes on this Notice to Keeper before I submit my first appeal to the operator.
This is a postal ANPR PCN from **GroupNexus / CP Plus Ltd t/a GroupNexus** for **The Orchard Centre – Main Car Park, Didcot**.
The alleged parking event was **6 August 2026**. The Notice to Keeper is headed **“Date of Issue: 18-08-2026”**. It actually arrived through the post on **21 August 2026**.
I have attached redacted photographs of both sides of the notice. The driver has not been identified and I intend to deal with this only as the registered keeper.
Having compared the NTK with Schedule 4 paragraph 9 of the Protection of Freedoms Act 2012, I think there may be several issues, but I would be grateful if somebody could confirm whether I have understood them correctly.
The main one I see is **paragraph 9(2)(f)**. I cannot find anywhere on either side of the NTK the required warning that, after the relevant 28-day period, if the charge remains unpaid and the creditor does not know the driver's name and current address for service, the creditor will (subject to the Schedule 4 conditions) have the right to recover the outstanding amount from the keeper. The notice merely says that if payment is not made they may ask a debt recovery agent to collect it. Am I correct that this is not equivalent to the 9(2)(f) keeper-liability warning?
I also think **9(2)(e)** may not have been complied with. The NTK says: “If you were not the driver then let us know their name and address and we will send them this Charge.” However, I cannot see the required statement that the creditor does not know both the driver's name and a current address for service, nor an instruction to pass the notice to the driver.
There is also a possible **timing issue**. The parking event was 6 August and the notice actually arrived on 21 August. My understanding is that the 14-day relevant period under 9(4)/(5) ended on 20 August. However, the NTK has a “Date of Issue” of 18 August, so I appreciate there may be an issue around deemed delivery and proving the actual posting/receipt date. I would particularly welcome views on this point.
A further possible issue is **9(2)(h)**. The document is prominently branded GroupNexus but states in small print “CP Plus Ltd T/A GroupNexus”. As GroupNexus Limited is now itself a separate incorporated company, is there a credible argument that the creditor has not been sufficiently identified, or would you regard “CP Plus Ltd T/A GroupNexus” as adequate?
Two weaker points I noticed are that it says “Date of Issue” rather than specifying the date it was actually sent, and the alleged contravention is described using generic alternatives: exceeding the free parking period, OR exceeding paid-for time, OR exceeding the maximum stay, rather than clearly identifying which particular contractual condition allegedly gave rise to this charge.
Before giving GroupNexus a detailed explanation of every potential defect, I was considering sending only the short keeper appeal below and preserving the detailed arguments for POPLA if they reject it.
**Proposed first appeal:**
“I am appealing this Parking Charge Notice as the registered keeper.
Your Notice to Keeper does not comply with the mandatory requirements of Schedule 4 of the Protection of Freedoms Act 2012 and therefore liability has not been transferred from the unidentified driver to the registered keeper. The notice was also not received until 21 August 2026.
The driver will not be identified.
Please cancel the Parking Charge Notice. If you decline to do so, please issue your formal rejection together with a POPLA verification code.”
Would experienced members recommend sending that as the initial operator appeal, or would you change/add/remove anything at this stage?
Thanks.