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

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Could millions of IPC PCNs issued since 1 May 2026 be unenforceable?

Read my Open Letter to the Chief Executive of the Chartered Trading Standards Institute (CTSI).

The CTSI is supposed to be managing the IAS through the transition from the weak 2015 ADR regulations to the fair, strict DMCCA 2024 regulations that went live in April. Instead, Government FOI disclosures suggest they are allowing the appeals service to be operated unlawfully—meaning the IPC's access to the DVLA could be fundamentally compromised.

22 October 2026

Chartered Trading Standards Institute

1 Sylvan Court, Sylvan Way

Southfields Business Park

Basildon

Essex, SS15 6TH

For the attention of John Herriman Chief Executive johnh@tsi.org.uk

OPEN LETTER by post and email

SUBJECT: NOTICE OF REGULATORY IRREGULARITY – Transitional Provisions and the Independent Appeals Service (IAS)

cc

Sojan Joseph member of Parliament for the Ashford Constituency sojan.joseph.mp@parliament.uk

Jacqui Guerreiro Interim Corporate Services Director jacquig@tsi.org.uk

xxxxx xxxxxx The ADR Competent Authority Team, CTSI adrenquiries@tsi.org.uk

Department for Business and Trade (BIST) Information Rights Unit FOI@businessandtrade.gov.uk

Dear Mr Herriman,

I am writing to formally challenge the regulatory basis upon which the Chartered Trading Standards Institute (CTSI), acting as the statutory Competent Authority, is permitting Accord Dispute Resolution Ltd to act in the administration and provision of the Independent Appeals Service (IAS).

Following a Freedom of Information disclosure issued by the Department for Business and Trade on 15 October 2026 (FOI2026/14086), the exact administrative position of the CTSI has been placed on the public record.

In their formal disclosure, BIST has confirmed the following regarding the CTSI's oversight of Accord Dispute Resolution Ltd and Unity (United Trade and Industry Ltd):

1. Operating under a 2015 legacy certificate:

"The Department holds the 2015 ADR approval certificate... No more recent certificate is currently available. The business in question continues to operate under this certificate during the transition between the 2015 ADR Regulations and the recently introduced 2026 ADR Regulations. At present the business is still within the transition process and is being assessed against the new 2026 ADR Regulations. The certificate will be reissued under the 2026 ADR Regulations to account for any changes since then, subject to the satisfactory completion of the transition process between the 2015 and 2026 ADR regimes...."

1. Endorsing an unseen contract:

"Neither the Department nor the Chartered Trading Standards Institute hold any further information or have access to contracts and licensing agreements between third party companies..."

As the Competent Authority, the CTSI’s current regulatory stance creates a severe corporate-identity discrepancy that appears to circumvent the Digital Markets, Competition and Consumers Act (DMCCA) 2024. I set out the specific regulatory concerns below:

1. The Abuse of Statutory Transitional Protection

The DMCCA 2024 revoked the 2015 Regulations on 6 April 2026. While the Commencement Regulations contain transitional provisions allowing existing providers to continue operating while applications under the new framework are considered, those provisions appear to be directed towards the legal entity that held the original approval.

Accord Dispute Resolution Ltd is a separate company incorporated in November 2025. Accord became the registered data controller for the IAS on 1 May 2026, and the IAS website publicly states that the IAS is a trading style of Accord Dispute Resolution Ltd.

The CTSI's published position appears to be that Accord is now responsible for the delivery of ADR services, whilst the business continues to rely upon a 2015 approval certificate issued under the former regime. It is therefore unclear what legal basis permits a newly incorporated company to benefit from transitional protection associated with an approval granted before its existence. If the CTSI contends that such protection is transferable, licensed or otherwise capable of extending to Accord, I invite the CTSI to identify the precise statutory provision upon which that position relies.

This question is particularly significant given the IAS's stated approach to dispute resolution. The DMCCA 2024 requires ADR providers to determine disputes fairly, lawfully and with regard to applicable Codes of Practice. By continuing to exclude operator misconduct and Code breaches from consideration, the IAS risks failing the core statutory requirement of fairness, raising serious doubt as to whether its present operating model is capable of satisfying the requirements for full accreditation under the DMCCA 2024 framework. In those circumstances, the continued reliance upon transitional arrangements becomes an issue of substantial public and regulatory importance.

2. The "Subcontracting" Contradiction

While an approved ADR provider may subcontract administrative IT functions, they cannot outsource the statutory responsibility for the ADR function itself.

The CTSI is trapped in a regulatory paradox:

• Scenario A (Subcontracting): If Unity remains the sole legal ADR provider and Accord is merely an administrative subcontractor, then the IAS’s public claim that "full legal separation" has taken place is false. The trade association's parent company is still legally conducting the appeals with its software and web interface. By ignoring this, the CTSI is permitting a severe consumer transparency failure.
• Scenario B (Actual Legal Separation): If Accord is the entity actually carrying out the ADR function, they are doing so without statutory accreditation and without transitional protection, raising serious questions as to compliance with Section 293 of the DMCCA 2024. The CTSI has already confirmed this reality in writing. In your letter to David Finney dated 1 September 2026 (enclosed as Annex A), the CTSI explicitly stated your understanding that Accord "is responsible for the delivery of the ADR service, including the handling and resolution of disputes." You cannot legally acknowledge an uncertified, newly incorporated entity as the provider responsible for dispute resolution while simultaneously allowing them to hide behind Unity’s non-transferable transitional protection.

3. Systemic Consumer Detriment

On 20 October 2026, the Government laid the new Private Parking Code of Practice before Parliament. The accompanying consultation explicitly relies on trade associations to apply their "existing sanctions processes" to protect motorists during the statutory transition to a truly independent single secondary appeals system that will replace IAS & POPLA

However, Freedom of Information disclosures from the DVLA confirm that the IPC has issued zero immediate operator sanctions. Concurrently, the IAS publicly refuses to consider operator breaches of the Code of Practice or driver mitigation during appeals, a stance wholly inconsistent with the DMCCA 2024 requirements of fairness and legality.

This creates a closed-loop system of accountability failure. The trade association issues no sanctions against its members, while the appeals service disregards operator misconduct when assessing disputes.

This business model is fundamentally incompatible with the accreditation standards imposed by the DMCCA 2024, which require ADR providers to resolve disputes fairly, lawfully and with regard to applicable Codes of Practice. By deliberately excluding operator rule-breaking from consideration, the IAS risks failing the core statutory requirement of fairness, calling into question its ability to obtain or retain accreditation under the DMCCA 2024 framework.

The CTSI is allowing the IAS to use the transition period as a regulatory shield to avoid reforming an appeals model which may be incapable of satisfying the standards required for full accreditation under the new regime.

Furthermore, the provision of a certified, lawful independent appeals service is a mandatory condition for operators to access DVLA keeper data under the KADOE contract, and a strict statutory requirement to pursue keeper liability under Schedule 4 of the Protection of Freedoms Act (POFA) 2012

If Accord Dispute Resolution Ltd has been operating the IAS without lawful statutory accreditation, the compliance chain underpinning the entire IPC operator network is fundamentally compromised. A lawfully accredited independent appeals service is a mandatory condition of the regulatory framework supporting access to DVLA keeper data under the KADOE contract and the operation of keeper liability under Schedule 4 of the Protection of Freedoms Act 2012.

By facilitating this arrangement, the CTSI has potentially undermined the legal foundation upon which IPC operators have continued to obtain DVLA keeper data and pursue parking charges since 1 May 2026. If the statutory basis for the IAS's operation is defective, the inevitable consequence is that millions of IPC parking charges may now be vulnerable to challenge on the basis that the regulatory safeguards underpinning the enforcement regime were never lawfully satisfied.

Required Action

The available public and FOI evidence strongly suggests the CTSI is permitting a corporate handover of a statutory function without having independently verified the underlying legal arrangements, demonstrated compliance with the DMCCA 2024 accreditation requirements, or obtained and reviewed the contractual documentation upon which the arrangement is said to depend. To clarify this regulatory discrepancy, I require you, as Chief Executive, alongside the CTSI Legal Department, to explicitly confirm the following by return:

1. Which specific legal entity (Company Registration Number) currently holds the transitional protection to carry out ADR within the DMCCA definition?
2. Has that specific legal entity submitted a timely DMCCA accreditation application, and on what date? Furthermore, please explicitly confirm whether any such application has subsequently been refused, withdrawn, or assessed as non-compliant with the new 2024 statutory requirements.
3. What statutory transitional provision permits Accord Dispute Resolution Ltd to act as the Data Controller and hold the IAS as a trading style from 1 May 2026?
4. Did the CTSI formally assess and approve this corporate restructuring, and if so, what documentary evidence was relied upon, given BIST's admission that CTSI does not hold the relevant contracts?
5. Did the CTSI independently verify the lawful basis for this arrangement prior to issuing its 1 September 2026 letter, or did the Competent Authority merely record an "understanding" of what it was told without conducting its own statutory due diligence? Furthermore, I require you to explicitly identify the specific parties (both corporate and individual) who provided this "clarification/understanding" to the CTSI.
6. Has the CTSI formally assessed whether the IAS’s stated policy of refusing to consider mitigation and operator Code of Practice breaches satisfies the mandatory statutory requirements for fairness and lawful dispute resolution under the DMCCA 2024? If so, please explain how the Competent Authority reconciles this policy with the new accreditation standards.

Should the CTSI fail to provide a substantive legal clarification of this arrangement within 14 days, I will draw the necessary inference that the CTSI cannot lawfully defend this arrangement. I will subsequently escalate this regulatory failure, supported by the enclosed FOI evidence, directly to the relevant Government Ministers via my Member of Parliament. My intent is to ensure this corporate discrepancy is subjected to urgent parliamentary scrutiny during the current 40-day laying period of the new Private Parking Code of Practice.

Yours sincerely,

xxxxx xxxxxxx

Enclosed:

Annex A_Redacted.pdf BIST/CTI 09 Approval of Accord Dispute Resolution Ltd

BIST Internal Review - IR2026_12204.pdf Freedom of Information review

Papermate2

The Illusion of Reform: Why the New Private Parking Code May Fail the Public

In late October 2026, the UK government finally laid the highly anticipated draft Private Parking Code of Practice before Parliament. On the surface, this statutory framework—born from the Parking (Code of Practice) Act 2019—promises a revolution. It boasts a mandatory Appeals Charter, strict new physical standards for car park signage, and the introduction of an independent Scrutiny and Oversight Board.

To the casual observer, it appears the Wild West of private parking is finally being tamed. But for those who have watched this multi-million-pound industry operate over the last decade, the reality is far more dismal.

Beneath the government's headline promises lies a labyrinth of transition periods, regulatory loopholes, and outsourced enforcement that threatens to leave the very same trade associations in the driving seat. Far from a fatal blow to predatory parking practices, the new Code may simply be the next evolution of a highly adaptable, deeply entrenched industry.

Here is why the public should remain deeply fearful of what comes next.

The Transition Trap and the Signage Loophole

The government's new framework is currently enduring a 40-day Parliamentary scrutiny period, followed by a 21-day enactment window. After this, the Code officially goes live, and the government will publish its transition rules. This transition period is the industry’s greatest weapon.

Historically, the government has been generous to operators. The aborted 2022 Code offered a staggering 21-month grace period. There is every reason to fear a similar, multi-year delay this time around.

The industry has brilliantly outmanoeuvred the government on this front. Originally, the parking trade associations (the BPA and IPC) mandated in their own joint Code of Practice that operators must update older, non-compliant signs by December 31, 2026. However, in a quiet but devastating update in April 2026, they abandoned this self-imposed deadline. They stated they would instead align with whatever the government decided.

By erasing their own deadline, the industry removed the government's strongest leverage. Operators can now claim they cannot possibly retrofit tens of thousands of car parks overnight, practically guaranteeing a long, drawn-out transition period.

During this time, the "signage loophole" remains wide open. Motorists will continue to be penalised by faded, hidden, and deliberately confusing signs, while operators hide behind the excuse that they are still within the government's transition grace period.

The Fox Guarding the Henhouse: The Survival of the IAS

The 2019 Act legally mandates the creation of a single, unified, fully independent appeals service to replace the industry-funded POPLA and the Independent Appeals Service (IAS). However, this new service does not yet exist.

Because the government cannot pause parking enforcement while they build the new system, they have effectively outsourced interim enforcement to the existing bodies. This means the IAS—an organisation with a notorious track record of dismissing legitimate appeals and protecting operators' revenue streams—is being trusted to enforce the new statutory Appeals Charter.

Furthermore, under the Digital Markets, Competition and Consumers (DMCC) Act 2024, the IAS is struggling to even certify under the new Alternative Dispute Resolution (ADR) regime, having been granted an extension to January 2027. Allowing a body that cannot currently meet modernised ADR standards to continue presiding over public appeals is a blatant failure of consumer protection. Expect the IAS to use every interpretive loophole during the transition to rule in favour of the parking companies that fund them.

The DVLA’s Abdication of Duty

The entire private parking model relies on one crucial mechanism: electronic access to the DVLA’s registered keeper database. Without the ability to demand names and addresses, operators cannot issue postal fines, and their business model collapses.

In theory, the threat of losing DVLA access should keep operators in line. In practice, the DVLA has entirely washed its hands of regulatory responsibility. Freedom of Information requests have explicitly revealed the DVLA’s stance: they view themselves merely as data administrators. They accredit the trade associations and then leave them to regulate themselves. The DVLA does not investigate operators, nor do they suspend companies for breaching codes of practice of their own volition. At the same time the trade does not sanction its operators per its own code which is merely window dressing.

While the new Code supposedly links DVLA access to compliance, the DVLA itself will not be the one pulling the trigger. They will wait for instructions from external watchdogs—watchdogs that the industry is already preparing to infiltrate.

Regulatory Capture: Infiltrating the Watchdogs

When the government replaces self-regulation with statutory oversight, an industry's immediate tactical pivot is toward "regulatory capture." The private parking sector will undoubtedly use its immense financial resources to influence, soften, and compromise the newly formed regulatory apparatus.

The new Scrutiny and Oversight Board is designed to be independent, but it is fraught with structural vulnerabilities:

1. The Funding Trap: The Board is expected to be funded by a levy on the parking industry itself. When a regulator's financial lifeblood is tied to the industry it polices, aggressive enforcement becomes politically and economically dangerous.
2. The Expertise Loophole: To function, the Board requires members who understand the highly specific mechanics of ANPR systems, land management contracts, and parking logistics. This creates a "revolving door" where former parking executives and industry lobbyists secure advisory seats under the guise of providing technical expertise, subtly bending the rules from the inside.

The Commercial Auditor Flaw

Finally, there is a fatal flaw in how the new rules will actually be audited on the ground. Operators will be required to be certified by a UKAS-accredited Conformity Assessment Body (CAB).

While UKAS sets the standards, the CABs executing the audits are commercial businesses. Parking operators will pay these companies to audit them. This creates an inherent, dangerous conflict of interest. Because CABs compete for the operators' lucrative business, there is massive commercial pressure not to be the strictest auditor on the market. If a CAB fails too many operators for poor signage or predatory grace periods, operators will simply take their money to a more lenient certifier. It is a recipe for "soft auditing" that allows bad practices to receive an official stamp of approval.

Conclusion: Flowing Against the Tide

The private parking sector has been likened to a cancer on the motorist—highly adaptive and incredibly difficult to eradicate. While the Parking (Code of Practice) Act 2019 and the new statutory framework are steps in the right direction, they are ultimately flowing against the tide of a well-funded, heavily entrenched industry.

Through extended transition periods, reliance on compromised appeals services like the IAS, the apathy of the DVLA, and the inevitable creep of regulatory capture, big business will find a way to maintain its grip. The rules of the game are changing, but make no mistake: the parking industry intends to keep dealing the cards.

Armageddon - Epilogue

For years, the private parking sector has operated as a creeping, unabated plague upon the consumer. But the smoke and mirrors of this new transition period have made one thing starkly clear: the plague has now escalated into a war.

The industry has systematically hijacked our legal framework, toxically transmuting consumer law into their own private gold rush. The traditional regulatory avenues are a dead end—they have already been co-opted, shaped and secured by the very warmongers we need protection from.

But with war comes the inevitable uprising. When the system is rigged, what can ordinary consumers do against the financial might of an industry that writes its own rules? How do we band together as an army to defend ourselves when the regulatory tide is against us?

I have a simple, entirely legal non-violent gem of an idea that would crush their revenue stream. Does anyone else?

Answers on a postcard please…