You are getting hung up on the wrong “28 days”. The Code does not give them 28 days from the date printed on the notice to shut the door on appeals. The PPSCoP talks about 28 days from when the keeper "receives" the notice, and then explains how “receipt” is worked out for something sent by post.
In your case the timeline is quite straightforward. The alleged contravention was on 28/10/2025. The Notice to Keeper (NtK) is dated 05/11/2025. The PPSCoP says that a notice sent by post is presumed delivered on the second working day after the date of posting, unless you can prove otherwise. If UKPC actually posted it on 05/11, the first working day is Thursday 06/11 and the second working day is Friday 07/11. So, for the purposes of the PPSCoP, the NtK is treated as received on 07/11/2025.
The 28-day appeal window in the PPSCoP then runs from that date of deemed receipt, not from the 5th. Count 28 days from 07/11/2025 and you land on 05/12/2025. That is the last day on which the Keeper must be allowed to lodge an appeal under the Code. You tried to use the online appeals portal on 02/12/2025, which is only day 25 from deemed receipt. In other words, your appeal attempt was comfortably within the 28-day period the PPSCoP requires.
Now put that alongside what the Code actually says. Section 8.1.2(e) requires that the notice itself tells the recipient they can appeal if they do so within 28 days of receiving the parking charge. The Note under that sub-paragraph is the bit that sets out the “second working day” presumption I have quoted. Section 8.4.1 then says that operators must provide a process which allows the parking charge to be appealed within 28 days, and at §8.4.1(c) it goes further and says they must consider late appeals where the motorist can show exceptional circumstances.
UKPC’s system blocking an appeal on 02/12/2025, and declaring that the case had been sent to debt recovery even though the 28 days from receipt had not yet expired, is flatly contrary to both 8.1.2(e) and 8.4.1(a). Even if they wanted to argue about when you actually got the NtK, your screenshots show that, taking their own issue date at face value and applying the Code’s deemed delivery rule, you were still well within time when you tried to appeal.
That deemed-delivery rule also contains the escape clause I pointed out: the presumption applies “unless the contrary is proved”. UKPC will be put to strict proof of the date the notice actually entered the postal system using a genuine first-class (1–2 day) service. They will not be able to do so. They invariably rely on hybrid-mail systems offering 2–3 day delivery with no individual proof of posting and no evidence of the exact day the NtK entered Royal Mail’s network. That is not proof of first-class posting, and it does not satisfy the evidential requirement of the Note in the PPSCoP. As soon as UKPC attempt to rely on the presumption, it is rebutted. In other words, your appeal window is not only intact on the deemed-delivery calculation, it is even stronger once the presumption is knocked out.
You captured screenshots of the online appeal page and payment page, showing the date and time when their system wrongly stated that appeals were closed and the matter was with a debt collector, while still happily offering you a £100 payment button. You have also sent a written appeal to UKPC in the keeper’s name, which does not identify the driver.
The narrative for the formal complaint and appeal is therefore simple: contravention on 28/10, NtK dated 05/11, deemed receipt on 07/11 under the PPSCoP, and an online appeal attempt on 02/12 which was within the 28-day period. The refusal to accept that appeal is a breach of 8.1.2(e) and 8.4.1(a). The previous written appeal must therefore be treated as an in-time appeal and processed accordingly, with either cancellation or a rejection including a POPLA code.
Section 11.2 of the PPSCoP then bites. That clause says that where a parking operator receives a complaint that it considers to be or include an appeal against the validity of a parking charge, it must treat it as an appeal for the purposes of the 8.4 timescales unless and until it is clear that the complaint is not relevant to an appeal. The complaint is plainly about the validity of the charge and the handling of the appeal window, so UKPC are required to treat it as an appeal under the Code.
The escalation narrative is then completed by noting that continuing to block an in-time appeal and pushing the consumer towards “debt collection” while misrepresenting their appeal rights is not only a PPSCoP breach but also an unfair commercial practice under the Digital Markets, Competition and Consumers Act 2024. This behaviour involves misleading actions and omissions concerning the consumer’s rights of redress, and the use of aggressive commercial pressure. It is conduct that may fall within the CMA’s enforcement remit under the DMCC. If the person reading the complaint does not understand the implications of that, they should pass it immediately to a responsible adult within UKPC who has the intellectual capacity to do so.
Finally, the keeper makes clear that if UKPC refuse to recognise the appeal as in-time or fail to issue a proper rejection with a POPLA code, the matter will be escalated to the BPA, the DVLA, and the CMA for breaches of the PPSCoP, misuse of DVLA data, and unfair commercial practices under the DMCC.
