That is simply the IAS deliberately making it extremely difficult for users. There is absolutely no other reason for this. It requires a CMA complaint which I will give you after I have stripped the response down to 1,000 words or les (another stupid and deliberate frustration for users with absolutely no reason).
As for the blocking of "paste" for text, here are some suggestions to get around that deliberate restriction:
Step by step guide for bypassing a webform that blocks pasting
1. First try the keyboard shortcut. On Windows or Linux press Ctrl+V. On a Mac press Command+V. Many sites only block right‑click paste but not the shortcut.
2. If that fails, paste your text into another box on the page or into a notes app, then copy it again and try pasting inside the form. Sometimes this works because the block only applies to the first attempt.
3. If the site still refuses, use your browser’s developer tools. On the page press F12. On Windows or Linux you can also press Ctrl+Shift+I. On a Mac press Command+Option+I.
4. Right‑click the box where you want to paste and choose Inspect. This shows the code for that box.
5. Look for anything that says onpaste or return false. If you see it, delete that part of the code. Close the tools and try pasting again.
6. If you do not want to touch code, install a browser extension. Search for Allow Copy or Enable Copy Paste in your browser’s extension store. Add it to your browser. These extensions automatically remove the block and let you paste normally.
7. Remember this block is only a nuisance. It does not make the form safer. Using shortcuts, developer tools, or an extension simply restores normal browser behaviour.
Here is the response reduced to under 1,000 words:
This is my response to the operator’s prima facie case. I rely on the following submissions to show that the parking charge is not recoverable and should be cancelled.
1. Failure to establish keeper liability under PoFA
The operator’s NtK purports to rely on PoFA by reproducing the warning in paragraph 9(2)(f). Having chosen to invoke statutory keeper liability, the operator must comply strictly with all mandatory conditions in paragraph 9. Any material defect is fatal.
The NtK fails to comply with paragraph 9(2)(e). That paragraph requires the creditor to state that it does not know the driver’s name and address for service, and to invite the keeper either to pay the charge or, if not the driver, to provide the driver’s details and pass on the notice.
The NtK does not contain the required statement that the creditor does not know the driver’s name and address, nor a compliant invitation in the terms envisaged by PoFA. Instead, it is framed mainly as a demand that the keeper pay, with a separate instruction that, if the keeper was not the driver, they “should notify” CPM of the driver’s details and pass the notice on. That is not the statutory wording and does not satisfy paragraph 9(2)(e). PoFA is a narrow derogation from the ordinary rule that only the driver is liable, so strict compliance is required.
Without full compliance with paragraph 9, the operator cannot transfer liability from the unidentified driver to the keeper. Any assertion of keeper liability in reliance on PoFA is misconceived. The only person who could, in principle, be liable is the driver, who has not been identified and whose liability has not been proved.
2. The driver was an authorised visitor engaged in deliveries, not an “unauthorised” parker
According to the NtK and signage, only vehicles “registered” with CPM and holding a valid e-permit may park, and others are treated as unauthorised. That framework does not fit these facts.
The evidence includes the driver’s delivery manifest from the material date and time. It shows three deliveries to addresses at Eagling Close within the 13-minute period relied on by the operator. The vehicle was present solely to perform those deliveries.
A delivery driver attending at the request of three occupiers is an authorised visitor, present under the implied licence and invitation of those occupiers, not on the land for personal convenience. Any suggestion that the vehicle was “not authorised” or “not permitted” to attend is therefore untenable.
3. Loading and unloading do not amount to “parking” on these facts
The signs regulate “parking” in marked bays and purport to prohibit parking on roadways, yellow lines and similar areas. They do not expressly address the temporary stopping of a commercial vehicle to load and unload parcels to residents.
Jopson v Homeguard [2016] distinguishes “parking” from temporary stopping for loading/unloading at residential premises and holds that brief stops to unload goods are a normal and necessary adjunct to the use of premises, not “parking” in the ordinary sense.
Those principles apply here. A 13-minute period to locate three properties, obtain access and deliver three parcels is normal loading/unloading activity. It is qualitatively different from static parking of the kind considered in ParkingEye v Beavis. There is no evidence that the vehicle was left for a substantial period, or that it occupied a marked bay contrary to any clear prohibition.
Any ambiguity as to whether the operator’s “parking conditions” extend to short delivery stops must be construed contra proferentem against the drafter. On a proper construction, the driver was not in breach of the signage. There was therefore no contractual breach.
4. Inconsistency between a permit-only scheme and the alleged contractual charge
The operator’s documentation adopts two inconsistent positions. On the one hand, CPM asserts that only vehicles pre-registered in its e-permit system are authorised to park, implying that other vehicles have no permission to be there. On the other, CPM asserts that every driver who stops is deemed to have accepted a contract to pay £100 for “breach of any term or condition”.
If a vehicle truly has no permission to park, at most there might be a trespass. Any cause of action in trespass belongs to the landowner, not CPM, and would sound in nominal damages only. Conversely, if CPM says that all motorists, including non-permit holders, are offered a contractual licence to stop on terms, then it cannot, in the same breath, describe the driver as “unauthorised”. The operator’s own characterisation of the vehicle as “not registered” and therefore unauthorised is inconsistent with the contention that a binding contract to pay £100 was nonetheless formed.
5. Unfairness and disproportionality of the charge
Even if, contrary to the submissions above, a contractual term were engaged, imposing a £100 charge on a delivery driver lawfully attending at the request of residents, for a brief period of loading/unloading, is penal and unfair.
The site is not a retail car park where there is a commercial justification akin to that identified in Beavis. There is no legitimate interest in imposing a large charge on delivery vehicles performing essential services to residents. The operator has adduced no evidence of any commercial or operational justification. The charge is out of all proportion to any legitimate interest and functions as a penalty, which is unenforceable at common law and unfair under the CRA 2015.
For all of these reasons, the charge is not lawful or recoverable in contract or statute. The appeal should be allowed and the Parking Charge Notice cancelled.
Whilst this will not help you right now, you should submit the following complaint to the CMA and use your evidence of frustration of the ability to respond to the operators prima facie case. It is very easy and straight forward. You are complaining about the IAS which is a trading name of United Trade and Industry Ltd, Cromwell House, Brook Street, Macclesfield, SK11 7AE. Use the following as the complaint text:
I wish to lodge a formal complaint against United Trade and Industry Limited, trading as the Independent Appeals Service (IAS). The IAS presents itself as an independent adjudicator of consumer disputes in the private parking sector. In reality, its processes are deliberately engineered to frustrate consumers and deny them a fair hearing.
The most egregious example is the restriction imposed on appellants when responding to an operator’s prima facie case. Consumers are limited to 1,000 words and are blocked from pasting text into the IAS webform. This restriction does not apply to the initial appeal, only to the rebuttal stage, where it matters most. Operators are free to submit extensive evidence and argument, yet consumers are deliberately prevented from responding in kind. This is not a neutral design choice; it is a calculated obstruction that suppresses consumer input and tilts the process in favour of operators.
These practices breach core principles of the Digital Markets, Competition and Consumers Act 2024:
1. Fairness and transparency in consumer contracts (Part 4, Chapter 1): Consumers must be given a fair opportunity to present their case. Arbitrary word limits and technical barriers are unfair terms in practice, as they materially disadvantage one party.
2. Prohibition of misleading and aggressive practices (Part 3, Chapter 2): By presenting itself as an independent adjudicator while deliberately restricting consumer participation, the IAS engages in a misleading practice. It creates the false impression of impartiality while structurally favouring operators.
3. Duty not to frustrate consumer rights (general consumer protection principles): The IAS’s deliberate blocking of text pasting is a direct frustration of consumers’ ability to exercise their right to challenge evidence.
4. Conflict of interest undermining independence: United Trade and Industry Ltd owns the International Parking Community (IPC), the trade association representing the very operators whose cases the IAS adjudicates. This dual role creates a structural conflict of interest. The IAS cannot credibly claim independence while being owned by the same entity that represents one side of the dispute.
Taken together, these practices amount to a breach of the DMCC’s requirement that consumer redress mechanisms be fair, transparent, and free from conflicts of interest. The IAS is not a genuine independent appeals service; it is a mechanism designed to give the appearance of fairness while systematically disadvantaging consumers.
I therefore request that regulators investigate United Trade and Industry Ltd’s operation of the IAS. The 1,000‑word limit and the deliberate blocking of text pasting should be condemned as unfair practices under the DMCC. The ownership link between United Trade and Industry Ltd and the IPC should be recognised as a structural conflict of interest that disqualifies the IAS from being treated as an independent adjudicator. Consumers deserve a process that enables them to present their case fully and fairly, not one that deliberately frustrates them for no legitimate reason.
https://www.gov.uk/guidance/tell-the-cma-about-a-competition-or-market-problem
Thank you for this. I have responded. I will revert here asa I get a response.
Hello and a Happy New Year.
So the response to the Prima Facie case was made on 02/12/2025 and I have received a reply from the IAS adjudicator on 11/01/2026 regarding this "vehicle unloading" matter.
The IAS adjudicator has dismissed the appeal.
What do you suggest I do now and what is likely to happen going forward?
TIA.
Below is a screenshot of the adjudicator's reply:
https://ibb.co/39KDxB6V
As in
Reply #2:
The IAS appeal will not be successful. The only way to not have to pay these scammers is to wait for them to try and litigate without (sic, should probably be through) the county court small claims track. That is when you would win this.
You will get letters from debt collectors, you don’t need to post them here, just tell us who and do not respond to them.
When you get a Letter of Claim, post it and we’ll advise a response.
Hello all.
So, I have received the first letter demanding payment from Debt Recovery Plus dated 9th February 2026 regarding an overstay in cul-de-sac in east London.
Any advice going forward please? Thank you.
All the info you need is in Jfellows' reply before yours.
Advice = Ignore debt letters.
Come back when you get a Letter of Claim or similarly worded document.
The PCN is definitely not PoFA complaint.
Thank yous for your advice.
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