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

Papermate2

https://forums.moneysavingexpert.com/discussion/comment/82180970#Comment_82180970

I have made some small edits and combined the entire body text. Are we happy to run with this combined prayer motion please? :-

I am urging you to lay or support a Prayer Motion to annul the Private Parking Code of Practice Statutory Instrument. The explicit drafting of this Code provides undeniable evidence that severe regulatory capture has already occurred during the consultation process. Rather than protecting consumers, the Government has completely acquiesced to the private parking industry's demands. If this framework becomes law, you can expect 20 million annual Parking Charge Notices (PCNs) to be issued against motorists, with absolutely no operators ever facing meaningful sanctions. I ask you to challenge this Code on nine specific, severe grounds:

1. The Legalisation of an Unlawful £70 Fee

The Code retains the £100 maximum parking charge and officially legitimises an arbitrary £70 "debt recovery" add-on fee. The Government’s consultation strategy of kicking the legality of this fee into the long grass is an absolute abomination of consumer justice. The Competition and Markets Authority (CMA) has previously indicated that these £70 add-ons likely breach consumer protection law. By codifying this fee in a Statutory Instrument now, the Government is cementing it permanently. How can any future legal review successfully strike this fee down as unlawful if the Government has already explicitly legalised it? Parliament must not rubber-stamp a practice that its own consumer watchdog considers a breach of consumer rights.

2. Consultation Hijacking and Sham Appeals The fact that Will Hurley, representing the International Parking Community (IPC), sat on the Government’s own steering committee explains exactly why the consultation was captured by industry interests. It is why he has publicly celebrated the laying of this Code, and why the new framework deliberately fails to dismantle the industry's closed-loop appeals system. Under the IPC's current "Independent Appeals Service" (IAS), the system outright refuses to consider driver mitigation or operator Code of Practice breaches. The operational commingling is so blatant that the Chartered Trading Standards Institute (CTSI) currently appears content that official correspondence from the IAS "Lead Adjudicator" is actively routed through the email account of Vicky Jarret—who is simultaneously the Head of Compliance for the IPC. The legality of the IAS's ongoing transition under the DMCCA 2024 (now fronted by a £100 shell company) is highly questionable, and formal challenges submitted to both the Government and the CTSI regarding the lawfulness of this setup remain entirely unanswered.

3. The Farce of Self-Regulation and DVLA Oversight Failure

The new Code explicitly relies on the industry to continue managing sanctions against its own members, but this self-regulation is entirely fictitious. Under recent Freedom of Information (FOIR12780) disclosures, the DVLA has formally admitted that the IPC has issued zero sanctions against its members. Furthermore, the DVLA is currently refusing to answer the exact same question regarding the British Parking Association (BPA), having gone completely silent for over 40 days past the statutory FOI deadline (FOIR13611-IR placed on 20 August 2026). . Astonishingly, this same ignored FOI internal review request suggests the DVLA does not even hold the founding accreditation documents for the BPA. The Code completely ignores this catastrophic oversight failure, allowing the industry to police itself while keeping its lucrative access to the DVLA database completely unchecked.

4. Hidden Transition Rules and Broken Promises on Signage

Crucially, the detailed transition rules for implementing this Code are being deliberately withheld and will not be published until after the Code becomes law, bypassing parliamentary scrutiny. The industry’s track record proves they will abuse any transition period. In April of this year, both the BPA and the IPC openly reneged on their previously published commitment to update all non-compliant car park signage by the end of 2026, halting improvements in favour of waiting to see whatever minimum standards the Government might require. Because the Government has acquiesced to almost every industry demand, it is highly likely these hidden rules will grant operators an excessively long transition period to comply. Once the 40-day laying period expires, MPs will have no power to challenge these loopholes, giving the parking industry a massive, unscrutinised grace period to continue exploiting motorists with defective signage under the old, failed system.

5. The Commercialisation of UKAS Certification and Lack of Independent Funding

While the Code introduces UKAS (United Kingdom Accreditation Service) certification as a purported safeguard, the practical mechanism guarantees further regulatory capture. Certification will be carried out by commercial Conformity Assessment Bodies (CABs) acting as service providers. Because these bodies will be paid directly by the parking operators they assess, they will inevitably monetise the approval process. Operators will simply "shop around" and employ only the CABs that offer lenient audits. Rather than driving up standards, this commercialised certification model creates a race to the bottom. Instead, both certification and the secondary appeals service must be established as government-controlled, unassailable functions. This oversight should be entirely self-funded through a mandatory statutory levy applied to the £2.50 KADOE fee that operators currently pay the DVLA for keeper data. This would instantly remove the industry's financial leverage over their own auditors and appeals bodies at zero cost to the taxpayer.

6. The Inadequate 30-Day Trap and Lack of Operator Penalties

The new Code introduces a highly restrictive rule stating that if a motorist pays a charge, any appeal to reclaim those funds must be made within just 30 days of payment. While framed as a consumer concession, this is a deliberate trap. Vulnerable motorists frequently pay illegitimate charges under extreme duress—simply to stop the harassment of the £70 debt recovery fee and the terrifying threat of court action. If definitive evidence of sharp practice comes to light after this arbitrary 30-day window—such as discovering the site relies on deliberately deceptive entrapment signage, as seen at Lythgoes Lane in Warrington where Euro Parking Services Ltd has brazenly breached the industry's current Code since March 2025—the appeals door slams shut permanently.

This strict cut-off must be abolished. Motorists must retain the right to reclaim extorted funds no matter how far back the incident occurred, in line with standard statutory time limits for fraud and misrepresentation. Furthermore, when a PCN is proven to be the result of deliberate entrapment, the Code must legally compel the operator to refund the charge with added interest and a statutory penalty paid to the motorist. Without this punitive mechanism, the Code provides a permanent, government-sanctioned shield for rogue operators to keep extorted funds with absolute impunity.

Furthermore, a leading consumer parking expert who actively served on the Government’s own Steering Group for this Code has blown the whistle on three additional catastrophic drafting errors:

7. Illegal Data Harvesting and Equality Act Breaches The Code allows operators to charge disabled motorists a £20 "concession" fee for failing to display a Blue Badge, but only in the "first instance." This is fundamentally unjust and breaches the Equality Act 2010, which requires full cancellation of the charge as a reasonable adjustment. Furthermore, enforcing this "first instance" rule forces operators to illegally harvest and store 'special category' health and disability data—in direct violation of the Data Use and Access Act 2025 and GDPR—for the sole purpose of blacklisting disabled drivers to deny future appeals.

8. The "Relevant Land" Two-Tier Loophole By restricting the statutory Code strictly to "relevant land," the Government is actively excluding tens of thousands of sites—including airports, drop-off zones, ports, council estates, TFL stations, and private tolls (such as the disastrous Warburton Bridge scheme). This creates a chaotic two-tier system: a limited statutory Code for some sites, and the continuation of an unregulated, self-serving "Wild West" for the rest. This drastically reduces existing consumer protections, encourages operators to invent "no-stopping zones" to bypass the rules, and totally reneges on the Government's promise to end self-regulation across all private parking.

9. The Unlimited "Tariff" Trap The Code introduces a catastrophic loophole allowing operators to double-claim charges where an unpaid parking "tariff" exceeds £60—without setting any upper ceiling on what that tariff can be. Rogue operators will inevitably weaponise this by erecting signs stating: "Free for 2 hours, £100 tariff thereafter." This allows them to instantly pursue vulnerable, delayed, or elderly shoppers for the £100 fake tariff plus the £100 PCN, hitting drivers with an immediate £200 demand. It is a naïve drafting error that serves as an open invitation for operators to print money at sensitive sites like hospitals, GP surgeries, and high streets.

Please urgently coordinate with your colleagues to raise a Prayer Motion to annul this Code before the 40-day period expires. It must be sent back to be stripped of the £70 debt recovery fee, the hidden transition rules, the unlimited "tariff" trap, and the illegal harvesting of disabled drivers' data. The Government must close the "relevant land" loophole to ensure the Code protects consumers across all private land, sever the industry-controlled access to the DVLA database, and instead mandate a reduced £60 maximum parking charge with a mandatory 50% early payment discount.

Nellymoser

Is this something that should also be sent to the House of Lords ?

https://www.parliament.uk/business/lords/whos-in-the-house-of-lords/get-in-touch-with-members/

Papermate2

https://forums.moneysavingexpert.com/discussion/comment/82181080#Comment_82181080

Yes, absolutely! That is a brilliant suggestion.

Because this Code is a Statutory Instrument under the negative procedure, it can be annulled by a motion in either the House of Commons or the House of Lords.

In fact, the House of Lords is often much more willing to challenge secondary legislation than the Commons because Peers are less restricted by party whips. The Lords also have a dedicated Secondary Legislation Scrutiny Committee that looks out for exactly this kind of regulatory capture and poor legal drafting.

The 9-point master document we are finalizing will work perfectly for members of the House of Lords. The only difference is that instead of a "Prayer Motion," they would technically raise a "Fatal Motion" or a "Motion to Regret," but the outcome is the same: it forces the Government to answer for this mess.

If we can target sympathetic Peers—especially those who champion consumer rights, transport, or disability advocacy (who will be absolutely appalled by the Equality Act breaches in Point 7)—it will double our attack surface.

If anyone knows of specific Lords who have historically spoken up for motorists or consumer rights, please list them here so we can coordinate and target them directly!

yarpsnehpets

Just a thought;

In terms of the 'relevant land loophole' - do we think that there is any chance that Government legislators simply assumed that land which is already under statutory control (where parking is controlled within the byelaws) constitutes land where a third party parking operator is unable to operate?

GrannyKate

AI came up with this list of interested peers

Peers interested in parking issues generally fall into two categories: those who have engaged with national legislation on private parking regulations and those who have dealt with internal estate parking arrangements (such as the Peers' Car Park at the Palace of Westminster).National Private Parking Legislation (Private Parking Code of Practice)Several peers have taken a prominent interest in consumer protection, private parking enforcement, and the implementation of the Parking (Code of Practice) Act 2019: [1]

Lord Hunt of Wirral (Conservative): Co-sponsored the original Private Parking Code of Practice Bill and has frequently led or contributed to debates pressing the government to curb aggressive tactics, opaque appeals, and excessive charges by private parking operators.Lord Lipsey (Labour): Raised key questions and short debates challenging delays in implementing the private parking code of practice and shared personal experiences regarding disputes with private parking companies.

Lord Lucas (Conservative): Tabled a regret motion and scrutinised statutory instruments relating to the private parking code and its impact on drivers and operators through the Secondary Legislation Scrutiny Committee.

Lord Sahota (Labour): Spoke out against the private parking industry, characterising aspects of the sector's fee models as unfair.Lord Kennedy of Southwark (Labour/Co-op): Voiced strong support for consumer-focused parking reforms and harsher crackdowns on abusive practices against motorists.

Baroness Randerson (Liberal Democrat): Contributed to debates on parking signage, regional rules (such as in Wales), and motorist fairness. [1, 2, 3, 4, 5, 6, 7]

Coupon-mad

Your shorter version is great!

Don't forget that the Civil Aviation Bill recently failed at Report Stage, on an amendment from the Conservative Peer Lord Moylan that forced the Government to conduct a review of the impact of airport drop-off charges.

He's got to be onside…

And The Lord Bichard KCB who not only sits in the Lords but he also serves as the Chair of the National Trading Standards Board, leading governance, delivery, and oversight of consumer protection enforcement across E&W.

We probably need a set of easy links to contact the likely Lords we want to see this, plus the shadow transport ministers.

And Baggy Shankar MP and Martin Wrigley MP who forced the May 2025 debate to take place about the Code of Practice.

Plus DEFINITELY the Housing, Communities and Local Government Committee:

https://committees.parliament.uk/committee/17/housing-communities-and-local-government-committee/

That's who Euro Car Parks, ParkingEye and Agena Group whinged to back in 2021/2022 and they were taken far too seriously because they strung some sentences together in the form of three letters.

If anyone uses Social media, use that to tag any of the above to a post about this.

Papermate2

https://forums.moneysavingexpert.com/discussion/comment/82181159#Comment_82181159

That was helpful thank you. Two have sadly passed and a third is a former member. I have written to the other two and I welcome any further recommendations from the community. It is quite straight forward to write to a member of the House of Lords, no region restrictions as is the case with MP's I also wrote a specific intro and exit as the terminology is not prayer.

Coupon-mad

Addressing members of the Lords 

Members of the House of Lords have a number of different titles, with different ways to address them.

Address some members using their title only, for example, Lord Sugar or Baroness Benjamin.

Other members have an additional part to their title which should also be used to address them, for example, Lord Collins of Highbury or Baroness Harris of Richmond.

• Find a member's title: A-Z list
• Learn more about the House of Lords by watching this explainer video.

Once you have found the correct title you can use the guide below which shows you how to use it in correspondence. 'X' should be replaced with the member's title.

Lord Speaker

• Beginning of email/letter... Dear Lord Speaker
• End of email/letter... Yours sincerely
• Envelope... The Rt Hon. the Lord Forsyth of Drumlean, Lord Speaker

Baron (Lord)

• Beginning of email/letter... Dear Lord X
• End of email/letter... Yours sincerely
• Envelope... The (Rt Hon.* the) Lord X

Baroness

• Beginning of email/letter... Dear Lady X
• End of email/letter... Yours sincerely
• Envelope... The (Rt Hon.* the) Baroness X

Countess

• Beginning of email/letter... Dear Lady X
• End of email/letter... Yours sincerely
• Envelope... The Countess (of) X

Duke

• Beginning of email/letter... Dear Duke of X
• End of email/letter... Yours sincerely
• Envelope... His Grace the Duke of X

Earl

• Beginning of email/letter... Dear Lord X
• End of email/letter... Yours sincerely
• Envelope... The (Rt Hon.* the) Earl (of) X

Lady

• Beginning of email/letter... Dear Lady X
• End of email/letter... Yours sincerely

Coupon-mad

https://forums.moneysavingexpert.com/discussion/comment/82181141#Comment_82181141

Nope. I think they re-read the Act and spotted the drafting error because this had never been mentioned in all the six years I've been on the Steering Group, until this year.

Just a thought: maybe the industry alerted them to it, and said they'd do a JR if the code covered more land than the Act defines. I don't know but that could have happened if the chancers saw an opportunity to put two fingers up and carry on BAU at airports, etc.

It might need swift legislation as an amendment to change the 2019 Act wording to cover non-relevant land, including places where parking is not offered/invited but is monitored by private parking firms, and drop off zones, no-stopping and private tolls. Basically, any private land - including land under statutory control - where parking (or private toll) companies operate and use surveillance or other methods to monitor vehicles using private land (parked or not) to issue notices of any type demanding money from motorists including drivers, hirers, lessees, fleet owners and registered keepers.

After all, they managed to amend the POFA to update railways into the definition of 'relevant land'. So they could amend the 2019 Act and push it through so a wider Code is bullet-proof.

And in doing so, bring in no-stopping zones, barrier-less (or barriered) drop-off zones and private tolls which is desperately needed to stop copycats of the notorious Warburton toll trap/scam.

Basically to leave no private land outside of scope and to kill the Warburton toll scam too, in one fell swoop.

Papermate2

https://forums.moneysavingexpert.com/discussion/comment/82181380#Comment_82181380

Thanks for the Heads up, I did get it right. One Lord had a direct email address and the other as a FAO.