Parking Code of Practice Consultation 2025 - now let's see what happens

Papermate2

@Coupon-mad

Yes indeed, the stars are aligning. A little relief for the tortured motorist.

For me, I finally have a successful Internal Review of a denied Freedom of Information request with the old DBT (now Business, Innovation Science and Technology... BIST).

I'm afraid that it gets somewhat technical here, but it is a shocking letter from the Chartered Trading Standards Institute (CTSI) who provide the "BIST" certificate that has allowed the IAS to screw the public with plain unfair, denied appeals since 2015, as they do not consider ANY mitigation or ANY operator breach of the Code of Practice (i.e., dodgy entrapment signs).

As you were saying, the April live DMCCA 2024 act is very important and has led Hurley to "employ" a new Lead Adjudicator (farewell Bryn Holloway who accepts any outcome as OK), who from 1 May 2026 became the new ADR for the IAS. The website no longer admits that the IPC owner administrates the IAS. It's now the new kid on the block, Lead Adjudicator, Solicitor David Gareth Finney himself with his new business, Accord Dispute Resolution Ltd (they love hijacking acronyms ADR). Incidentally, I did ask the CTSI to remove 'Independent' from the name IAS, but they explained that was out of their scope. Pity, but worth a try.

Sorry it's all a bit technical and boring, but the punchline will be worth it.

The certifying certificate for the IAS has always been with Unity, United Trade and Industry Ltd—the owner of IPC and IAS. IPC writes the rules and IAS ignores them, honest. The certificate is dated 14 September 2015 and continually renewed. That's all Hurley 100%.

The government-produced letter from the CTSI that they call "09 Accord Approval" Annex A is the shocker. Accord Dispute Resolution have NOT been approved by the CTSI. The CTSI think that Accord has a licence from Hurley and they think that's OK, they think. Anyone with a fine eye for a legal document will laugh at the following letter from the CTSI. Here we go, hope you can all see the funny side of it (I wish I could upload PDFs):

Mr David Finney
Director of Accord Dispute Resolution Ltd

Sent via email

1 September 2026

Dear Mr Finney

We write to confirm that, following clarification received today, we understand that Accord
Dispute Resolution Ltd contracted on licence on the 1 May 2026 with Unity (United Trade and
Industry Ltd) to act as the provider of ADR services for the Independent Appeals Service (IAS).

Based on the information provided, Accord Dispute Resolution Ltd is responsible for the delivery
of the ADR service, including the handling and resolution of disputes falling within scope.

This letter records our understanding of the position as clarified to us today. Should any aspect
of this arrangement change, or if our understanding is incorrect, please notify us as soon as
possible.

If you have any questions regarding this matter, please do not hesitate to contact us.

Kind regards.

Yours sincerely
Section 40(2)
Section 40(2)
ACS & ADR Manager

CTSI incorporated by Royal Charter
The CTSI group is comprised of the Trading Standards Institute (Reg. No. 38769) and itsa ltd (Reg. No. 2767942), both registered in England and Wales at 1 Sylvan Court, Sylvan Way, Southfields Business Park, Basildon, Essex SS15 6TH. Group Vat reg no. 795 8626 60.

______________________________

I reckon the clarification is Hurley telling the CTSI to do what he says or else, and CTSI are just botty covering with the Government. Look at the 4-month delay between Accord's licence on 1 May and CTSI faking an approval on 1 September.

CTSI refused to tell me and others, who had their certificate for the IAS. The government said they didn't have it and I had to start an internal review. That was a major fight, but the interesting thing is, at the point when I first asked if Accord had a certificate to be the ADR... Neither CTSI nor the Government could come up with an answer until September.

I think Coupon-mad will be well aware of the significance and power of this letter. I'm happy to copy you the PDF and BIST FOI review via private message if that would be helpful to you at the steering group.

What do you think Coupon-mad?

PS WOW get the ICO onboard a big ask, but would be great. I found they ignored me and I do mean ignored Euro Parking Services Ltd lying that they had cancelled a charge the same day they posted the Final Court Action letter. I presented proof of the impossibility of that. They also failed to redact full consumer registration plates, not end of world crime, but in ICO parlance a definite no no. My ICO complaint was substantial with the EPSL just an element, but ignored even on internal review as a specific point, One day I will do the PHSO case, but I have bigger fish to fry at the moment plus a holiday… Yaaaay.

Protest

I would be surprised if an unlicensed entity could be employed in the manner described by Papermate2 - to which AI responded…….

Your instinct is broadly right, but the new legislation contains an important wrinkle which makes the CTSI letter more interesting rather than automatically fatal to the arrangement.

Since 6 April 2026, Part 4 Chapter 4 of the Digital Markets, Competition and Consumers Act 2024 has replaced the old 2015 ADR regime. The fundamental change is that accreditation is now compulsory: a person cannot carry out consumer ADR unless accredited, exempt, or operating under permitted “special ADR arrangements” made by an accredited/exempt ADR provider. (Legislation.gov.uk)

And that third possibility looks very much like what Unity/Accord may be relying upon.

What the Act actually allows

Section 293 specifically envisages an accredited ADR provider arranging for another person to carry out the actual ADR on its behalf. The explanatory notes even say that the other person might be called a case handler, adjudicator or ombudsman and might be employed or engaged by the accredited provider. That other person does not require separate accreditation, provided the principal ADR provider is accredited/exempt and its accreditation permits it to make those “special ADR arrangements.” (Legislation.gov.uk)

So the crucial question isn't simply:

“Does Accord have its own CTSI accreditation?”

It is:

“Is Unity the accredited ADR provider, and does Unity's accreditation authorise it to make special ADR arrangements under which Accord carries out the IAS adjudication on Unity's behalf?”

If the answer is yes, Accord apparently does not need its own accreditation.

But if Accord has actually taken over the IAS and is itself the ADR provider, rather than merely carrying out adjudications on behalf of Unity, I think there is a potentially serious problem. Section 293(1) expressly prohibits an unaccredited person from carrying out ADR except within those permitted circumstances. (Legislation.gov.uk)

And that makes the CTSI letter rather peculiar

Read the wording you obtained again:

“Accord Dispute Resolution Ltd contracted on licence ... with Unity ... to act as the provider of ADR services for the Independent Appeals Service.”

and:

“Accord Dispute Resolution Ltd is responsible for the delivery of the ADR service, including the handling and resolution of disputes...”

That doesn't immediately tell us whether Accord is merely operating under a statutory special ADR arrangement, or whether it has effectively become the ADR provider.

More strikingly, CTSI merely says this is its “understanding”, based upon “clarification received today.” It doesn't say:

Unity is the accredited ADR provider; its accreditation permits special ADR arrangements under s.293(2); Accord is carrying out ADR pursuant to such an arrangement.

That would have disposed of the issue rather neatly.

There is another complication — transition

The new regime came into force on 6 April, but transitional provisions protected existing ADR operations while accreditation applications were being dealt with. Originally that transition was due to expire on 5 October 2026. Just last week, the Government extended it to 7 January 2027. (Legislation.gov.uk)

So I would be cautious about concluding that Accord has been operating unlawfully since 1 May. There may be transitional protection, depending upon precisely who has applied for what and how Unity/Accord's arrangements are characterised.

But your FOI has, in my view, exposed a very good regulatory question.

Rather than alleging that CTSI has “faked an approval”, I'd press them with something much harder to evade:

1. Is United Trade and Industry Ltd currently the accredited ADR provider for the IAS?

2. Does its accreditation expressly permit it to make “special ADR arrangements” within sections 291(7) and 293(2) DMCCA 2024?

3. Is the arrangement between Unity and Accord Dispute Resolution Ltd such a “special ADR arrangement”?

4. If so, on what date did CTSI satisfy itself that the arrangement complied with the Act and Schedule 26 accreditation criteria?

5. If it is not a special ADR arrangement, what statutory basis permits Accord to carry out ADR without its own accreditation?

Schedule 26 matters because accreditation isn't merely a piece of paper. The accredited provider has continuing obligations concerning expertise, independence, impartiality, transparency, procedures and consumer information, and those criteria expressly contemplate ADR undertaken through special arrangements. (Legislation.gov.uk)

So I wouldn't yet say “Accord is unlicensed and therefore shouldn't be adjudicating.” The legislation specifically provides a route by which it can.

I would say: CTSI's September letter does not, on its face, establish which statutory route makes Accord's activities compliant. Given that Accord apparently started on 1 May and CTSI was still recording its “understanding” of the arrangement on 1 September, that is a perfectly legitimate question to pursue.

And I think that is considerably stronger than the original correspondent's speculation about Hurley telling CTSI what to do. The documentary/legal question is good enough without the speculation.

Something for post-holiday consideration?

Papermate2

@Protest

Thank you for your in depth analysis, nothing is every easy with Private Parking. I can tell you that Unity (United Trade and Industry Ltd) has been certified by CTSI since September 2015 having completed a 2026 DMCC Audit. CTSI's letter is dated 1 September 2026 and was the file was provided as file O9 Accord Approval. CTSI's position was not this on 1 May but 4 months later after I pushed BIST for "who is certified for IAS". Crucially, the licence seems critical, and I have a FOI requesting this though somehow, I know t wont be that easy. Thank you for your interest, I will review after my holiday. I rather wish this would all go away but 16.9 million reasons to persist. Thanks @Protest

Papermate2

For anyone interested, here is a screen grab of the official CTSI letter which according to Department of Business Innovation Science and Trade, is the CTSI (and therefore it's own) Approval for Accord Dispute Resolution Ltd for the Independent Appeals Service (IAS)

Coupon-mad

https://forums.moneysavingexpert.com/discussion/comment/82150263#Comment_82150263

The dates are especially odd because David Finney has been Lead Adjudicator since 2025:

https://theias.org/ias-annual-report

The most recent report a year ago, was by him.

Nellymoser

A new uk parliament petition added today

https://petition.parliament.uk/petitions/780926

Closes 30 March 2027.