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

Papermate2

https://forums.moneysavingexpert.com/discussion/comment/82184832#Comment_82184832

Thank you. To be honest, it did feel a bit like pushing water uphill trying to create a template that would work for a wide response from MPs across the whole country. I am very happy to ease off, and it will be good to see a different approach.

It has felt like a heavy responsibility simply because we are so short of time before the 30 November deadline when the 21 days start. It will be great to see something from those of you with far more long-term experience with this than me, especially since this week is swallowed up by the Budget anyway.

I will wind back the enthusiasm for now so we don't cross wires, but I remain fully prepared to help and share my FOI's and other documentary evidence whenever you need it, and to help in any practical way I can. I have tried doing this stuff on my own for over one and a half years now. I've learnt a great deal, but I feel I have achieved little other than managing to get Hurley to remove his DVLA advert from his website! :)

BlueonBlue

As followers of this via MSE we only hear of what you and Coupon Mad do via both your posts on here !

Personally I think its great !

Papermate2

https://forums.moneysavingexpert.com/discussion/comment/82185141#Comment_82185141

Thank you I really appreciate that, so moving forward, this is simply a News item and I didn't write it.

I gave Claude my FOI 12780 and this prompt “how would you write the story about ATA IPC/IAS and DVLA during the transition period”:

While there can be mistakes it seems close to the point and perhaps some ammunition in there?

The transition gap: who polices private parking before the oversight board exists

The Government has promised independent oversight of private parking. Its own paperwork shows the board that would deliver it does not yet exist, no date is attached to it, and the two previous deadlines for establishing it were missed. In the meantime, the DVLA's own Freedom of Information responses show the MOU-based safeguards it relies on are not being exercised in the way the framework assumes.

What is being asked of Parliament

On 20 October 2026 the Government laid the Private Parking Code of Practice before Parliament, fulfilling its duty under the Parking (Code of Practice) Act 2019. Parliament has 40 days to scrutinise it; it comes into force 21 days after issue, and the Government's intention is to issue it on 30 November 2026 — meaning force in late December, subject to no objections.

The Explanatory Memorandum tells Parliament the protections are real. Accredited parking associations "that fail to meet the standards of the Code may lose their accredited status." The compliance framework "ensures that there is independent oversight over the private parking sector." It sets out why this matters, conceding that under the old regime "the absence of independent oversight, coupled with differences in auditing approaches and limited transparency around enforcement activity, undermined confidence that standards were being applied consistently across the sector."

That is an unusually candid admission — because it is a description of the regime that will still be running when the Code takes effect.

The board that is meant to close the gap does not exist

The independent Scrutiny and Oversight Board is the centrepiece of the new framework. Paragraph 10.2 of the Explanatory Memorandum says only that it "will be established." No date. No commencement provision. No transitional safeguard standing in for it.

The Impact Assessment, as summarised in the Regulatory Policy Committee's opinion, refers to "establishment of the Scrutiny and Oversight Board within one year." On the Government's own timetable — issue on 30 November 2026, force in late December — "within one year" points to late 2027, not to any earlier date. Claims that the board will arrive in Summer 2027 are not, on the record I can find, sourced to any Government statement. Anyone putting that date in print should be able to cite where the Government said it. At present, nobody can.

What the record does show is a pattern of slippage:

• February 2022: the minister told the Commons the certification scheme and oversight board would be established "this spring," with the transition period ending "End of 2023."
• July 2025: the consultation still described the board as a proposal, saying the Government "will work with the trade associations to work out transitional arrangements."

Four years after the board was promised, and with the Code about to take effect, there is still no published date for it — and an enquiry has been launched covering debt recovery and the Competition and Markets Authority's April 2026 concerns. Each of those rounds extends the period in which the old arrangements do the work.

What the old arrangements actually are

Until the board exists, the sector is policed by the two accredited trade associations — the British Parking Association and the International Parking Community, trading through United Trade and Industry Ltd — and by the DVLA, which controls access to vehicle keeper data through the KADOE service.

The architecture is layered and, on paper, admirably specific:

• Operators cannot request keeper data unless they belong to an ATA. Membership is the gateway to enforcement.
• The ATAs operate a code with a sanction scheme: 12 points as the upper threshold, Level 1 at 2 points through Level 4 at 9 points plus suspension or expulsion.
• The MOU between DVLA and each ATA obliges the ATA to notify DVLA when an operator accumulates 10 or more sanction points in a single instance, or 12 or more on accumulation.
• ATAs must tell DVLA within 24 hours when they suspend or expel a member.
• ATAs that fail to enforce their code "could lose their DVLA accreditation."

On paper, a closed loop. The question is whether the loop closes in practice.

What the FOI record shows

A Freedom of Information request to the DVLA (FOIR12780, answered 13 October 2025) asked directly. The answers are worth setting out plainly:

On MOU governance: DVLA holds no recorded information on Director-level or operational-level meetings between itself and the IPC, because "there have been no meetings at Director or operational level between the DVLA and IPC since 1 January 2023." The MOU's own two tiers of governance have not convened in almost four years. DVLA added, outside the Act, that "fortnightly catch-up meetings have been held between both parties to discuss compliance issues" — a candid contrast between the structure the agreement creates and the informal channel that has replaced it.

On audits and reviews: DVLA holds no records of any formal review or audit of the IPC's compliance with the MOU.

On breaches: DVLA holds no record of a single logged MOU breach by the IPC between January 2023 and the date of the request.

On sanction points: "the DVLA has not received any notifications from the IPC regarding sanction points awarded to its members."

Set against the MOU's requirement that high-point cases be notified immediately, that last line is the most significant in the response. Either no IPC member has reached the notification thresholds in nearly four years — implausible for a sector issuing charges on an industrial scale — or the notification mechanism is not operating. The DVLA's own earlier position supports the second reading: in a 2020 decision notice it told the Information Commissioner that occasions when either ATA had notified it of an expulsion were "rare: just one since 2012."

The response also shows what DVLA does do. It received 10 complaints about Euro Parking Services Ltd since September 2023 and upheld two; it supplied complaint breakdowns by company for three financial years; it disclosed the current MOU with the BPA and a KADOE contract. Keeper-data income rose from £13.18m in 2020/21 to £37.46m in 2024/25. This is not an idle agency. It is an agency doing a different job from the one the framework assumes.

The gap between the two jobs

DVLA states its position without ambiguity: "the DVLA cannot directly regulate the practices of private parking management companies and does not accredit the appeals services operated by the accredited trade associations." Its audits of parking operators, as the ICO recorded in 2023, "concentrate on the fair use of information disclosed from DVLA records, rather than on the level of ATAs' effectiveness and performance." Its assurance is contractual and data-protection based — is this request valid, is this data secure — not regulatory in the sense a motorist would understand.

So there is a structural hole. The ATAs police standards, but are not independent. The DVLA polices data use, not conduct. The board that would provide independent oversight of standards has no established date.

The appeals problem: the sharpest edge

The Independent Appeals Service is operated under the IPC's corporate umbrella — a trading name of United Trade and Industry Ltd, which also owns and operates the IPC, which administers the IAS. The MOU, on the account given in the same FOI response, relies on the competence and understanding of IAS barristers on key legal issues.

The DVLA's answers here are stark:

• It holds no records of any assessment of IAS independence.
• It holds no records confirming the competence and understanding of IAS adjudicators.
• It holds no contact information for the IAS at all — while naming the IPC's CEO, Head of Compliance and Head of Membership & Relations as its compliance contacts.
• Its assurance rests on having "been assured" adjudicators are independent, and on the service's certification by the Trading Standards Institute as an Alternative Dispute Resolution provider.

That is not evidence of a failure of will. It is a statement of remit: none of this is DVLA's to assess. But the consequence is that an appeals service structurally embedded in the body it hears appeals against is the standard motorists must use during the transition period, operating under a statutory Code that has not yet activated the body meant to scrutinise it.

How to frame it

The strongest version of this story is not "the DVLA is failing to enforce." The FOI record does not support that, and asserting it invites a correction that will damage everything around it. The defensible version is about remit, not conduct — and it is stronger for being so:

1. The Government promises independent oversight as the remedy for a regime it describes as lacking exactly that. The board delivering it has no date, no commencement provision, and two missed deadlines behind it.
2. Parliament is being asked to approve the Code without being told when the oversight it relies on begins. The transitional arrangements are promised for publication on GOV.UK when the Code comes into force — after scrutiny, not before it.
3. DVLA's own FOI responses show the MOU's structural safeguards are not in use. No Director-level or operational meetings in nearly four years; no audits; no logged breaches; no sanction-point notifications. Against a background where DVLA has said expulsions are "just one since 2012."
4. The interim safeguards are partly self-reporting. Operators must self-report breaches within three working days; the ATAs investigate and sanction; DVLA's own oversight is contractual and data-focused. That is not improper — it is what the accredited model was designed to be — but it is not independent oversight, and it is being asked to hold the line for a further period of indefinite length.
5. The independence of the appeals function rests on assurance, not assessment. Nobody in the current arrangement has assessed it, because nobody has the remit to.

Claims to drop or fix

• Do not date the board to Summer 2027 unless you can cite the Government's words. Say instead: no date given, two deadlines missed, IA refers to within one year of commencement.
• Do not attribute the audit-and-breach findings to FOI 12780 as a whole. Attribute each finding to the specific question it answers, and note that the same response supplied complaint data, contracts, income figures and annexes — that candour is a feature of the story, not a threat to it.
• Correct the record on paragraph number. The "independent oversight" and "may lose accredited status" language sits under section 6, "How has the law changed?", not at 6.1. Quote it accurately; a parliamentary committee will check.
• Pull FOIR12814 and FOIR12901. FOIR12814 came back "Fully met" — DVLA has a real number for IPC suspensions and expulsions since January 2020 and disclosed it. That figure, not a "not held" line, should anchor the enforcement question. FOIR12901 lists KADOE suspensions from January 2023. Until those are in hand, the inference of inactivity is asserted rather than evidenced.

The story writes itself once the supporting documents are attached: a Government that has named the disease precisely, prescribed the cure for four years running, and is now asking Parliament to approve a period of treatment during which no doctor is yet scheduled to arrive.

___________________________________________________________________

Not a bad analysis. I wish we could pull the FOIs gathered from public headers, but unfortunately, that is not possible.

What is a truly strong argument here is the immediate danger: during this unknown transition period, the IPC and its toxic, anti-consumer IAS will simply march forward, past the DMCC revised 7 January 2027 deadline, until the CTSI decides whether their ADR application is granted, refused, or withdrawn.

That decision is likely some time away—potentially long after the Government's own transition takes place. Don’t hold your breath.

So, my conclusion is admittedly pure speculation on my part, but if I were a betting man... more of the same sounds highly likely. "A Government that has named the disease precisely, prescribed the cure for four years running, and is now asking Parliament to approve a period of treatment during which no doctor is yet scheduled to arrive."

Papermate2

Thought for the week

I'm just waiting for the establishment of the Scrutiny and Oversight Board then leaning that Will Hurley has been appointed to head it because of his industry experience!

Coupon-mad

I like Claude but it is so obviously AI it immediately loses credibility.

It's to do with the headings, the long words and how stupidly long it is. Clearly a bot. Never use stuff like that without re-writing and making it more on-point and concise, and without the excitable AI sub headings!

Papermate2

https://forums.moneysavingexpert.com/discussion/comment/82185803#Comment_82185803

Fair point on the AI formatting! I actually don't intend to use that text for anything myself, so I won't be recompiling or rewriting it. I purely posted it up there for the community to consider the underlying theory and see if it sparked any ideas.

It introduced a lot of other information like the government continually pushing out the Scrutiny Board and independent appeals prior to settling on the actual Statutory Instrument. It didn't need to be that way. Also, I was unaware that there is already information showing there has only been one case where an operator was sanctioned, a good indicator that the ATAs don't enforce their own rules. From their perspective, why would they? They know they are getting away with not following their own code. The money carries on talking. Anyway, I think the sanctions part of the code was written as window dressing only. Looks good, but not used in the real world.

Setting the "bot-speak" aside, do you think the core argument itself, the transition gap and the complete lack of ATA oversight (and in the IAS case, unwinnable appeals regardless), has any value as a strategic angle for us to push in our final, human written drafts?

Coupon-mad

I'm not convinced the lack of APA oversight is a relevant point because one of the positives of the Code is the independent Scrutiny, such that hopefully even the CABs might be independent, if there is interest other than from the damn APAs setting up pseudo 'arms length' offshoots.

If anyone wants to do a bit of research over the weekend to find companies whose work includes acting as 'certification bodies' or governance consultants (any sectors) who might be interested in the below, please post a list and some posters here can take a few minutes to email those bodies this link:

https://www.ukas.com/resources/latest-news/expression-of-interest-accreditation-programme-for-private-parking-code-of-practice-certification-scheme/

"UKAS is inviting expressions of interest from organisations either operating as or intending to operate as certification bodies wishing to participate in a new accreditation development project for ISO/IEC 17065, to certify against the Government’s new Private Parking Code of Practice Certification Scheme."

It would be fabulous if the CABs were not related to industry APAs. We have two weeks to drum up alternative interest.

If we do nothing, we all know who will apply.

Maybe transport-related (or any sector) governance consultants, experienced ISO certification firms or other regulatory compliance experts who do similar work?

I found NQA, and these maybe?

AI says:

1. Broad-Spectrum & National Bodies

• BSI (British Standards Institution): As the UK’s National Standards Body, BSI is the largest and longest-operating certifier. They provide intense scrutiny across structural compliance, data security, environmental standards, and product marking. [1, 2]
• British Assessment Bureau (BAB): Part of the Amtivo Group, BAB specializes in evaluating companies against rigorous international and British regulations (such as ISO 9001, ISO 27001, and BS 10800). [1, 2]

2. Major Global Inspection & Certification Firms (UK Divisions)These multi-national firms maintain extensive UKAS-accredited teams in the UK to audit corporate conduct and supply chains: [1]

• SGS United Kingdom: One of the global leaders in inspection, verification, and testing.
• LRQA (Lloyd's Register Quality Assurance): Highly utilized for evaluating heavy industries, engineering, energy, and manufacturing conduct.
• Bureau Veritas UK: Conducts strict compliance checks against health, safety, environmental, and quality standards.
• NQA (Kiwa): Focuses heavily on commercial and enterprise management systems compliance. [1, 2]

3. Sector-Specific Specialists

• Alcumus ISOQAR: Known for accessible compliance testing and certification for small-to-medium UK enterprises.
• National Security Inspectorate (NSI) & SSAIB: Specialist UKAS-accredited bodies focused entirely on inspecting and certifying the conduct of fire safety and security firms.

🔍 Verification NoteUnder strict UKAS neutrality laws, an accredited firm cannot provide internal consultancy to a company they are auditing.

Papermate2

I completely agree with you on the danger of the APAs setting up shell companies to act as CABs. In fact, this is exactly the “regulatory capture” fear I flagged as Point 5 (The Commercialisation of UKAS Certification and Lack of Independent Funding) in the 9-point briefing I shared previously and sent to my MP.

Finding genuinely independent auditors like BSI to step into that UKAS role is a brilliant shout, though I have no history or connection with them and doubt an email from me would mean anything. In any event, the CABs the trade will use will be the ones they want and have either infiltrated or, as you say, set up dummy arm’s length companies for. Even with quality, real CABs, that will not stop the industry controlling it. Think about it: the industry must be knocking out over £1 billion a year turnover. Us little people are well and truly f*****! We are outclassed by an industry that has bastardised the government code. It makes me want to weep, I really its that bad. Please, please convince me I have got it all wrong.

Sorry about that drift, let’s get back on track. From a campaign perspective right now, my concern isn't just about the final architecture of the Code once the Scrutiny Board and the CABs are finally operational. My concern is the Transition Period (which I fear will be long) between now and then, with the IPC and IAS still cheating the public under a government veil of respectability.

As your UKAS link shows, they are only just asking for “expressions of interest” for the certification scheme right now. The Scrutiny Board has no commencement date. Implementing an ISO scheme and training auditors across the country will take ages.

During this massive transition gap, the CABs and the Scrutiny Board will not exist to protect anyone. The Government's own documents (the Options Assessment) explicitly state that during the transition, they are relying entirely on the existing ATAs (BPA/IPC) and their existing appeals services to hold the line. This is (one of) my targets to justify stopping the SI. Surely it has some merit?

I am not disputing that the final Code has independent scrutiny designed into it, if we can stop the APAs hijacking the UKAS process, as you rightly point out! My point is also that Parliament is being asked to approve a potential multi-year Transition Period where that scrutiny doesn't exist yet, leaving motorists entirely at the mercy of the current ATAs until those CABs are finally up and running. Is that transition gap not our strongest angle of attack right now? The industry got everything it wanted from the new code, I think it will be the same for the transition length, even though new signs are a quick sticky label.

Let me put it this way: Parliament has a chance to scrutinise the SI, but NOT the length of the transition period or its exact terms. Let's be afraid!

I don’t wish to be the voice of doom in the community, so I’ll leave this intelligence here for the Regulars to chew over. I will step back from drafting on this specific angle, but I remain here to help with the campaign however I can.

Official Documentation Confirming the Transition Trap:

The official Explanatory Memorandum attached to the SI explicitly states: "The transitional enforcement arrangements for new standards will be published on GOV.UK when the Code comes into force."

Furthermore, the final paragraph from the Private Parking Code of Practice: government response (Updated 20 October 2026) openly admits the ATAs remain in charge:

“While UKAS has recognised the Certification Scheme, a further period is necessary for it to evaluate conformity assessment bodies once organisations come forward to fulfil that role. The process is expected to take until around April 2027. In the meantime, the trade associations will continue to apply their existing sanctions processes, including the allocation of sanction points, with the ultimate sanction being the loss of access to DVLA data, under section 5(2) of the Act.” YEAH RIGHT

Papermate2

Email wise, is this the sort of thing we are looking for, tailored to suit the individual of course:

This one is to SCCS owned by the BCSA a longshot at best.

Subject: UKAS expression of interest for Government Statutory Instrument laid before Parliament 20 October 2026

Dear Sir/Madam,

A brief introduction: I was the Company Buyer for xxxxx xxxxx Ltd for over 20 years before I retired in 2018, hence I am aware of your integrity in UKAS certification.

I am with a group interested in garnering support for quality CABs to link with the UKAS expression of interest for bodies to certificate Operators in the Government’s Private Parking sector.

It’s clearly not anything to do with steelwork, and I suspect it is probably not something of interest. However, as a diversification long shot, I thought I would ask, as I have dealt with your auditors over many years and know that you are a genuine, trustworthy business.

I thank you for your kind attention and look forward to hearing from you.

Kind regards,

canuk_UK

https://forums.moneysavingexpert.com/discussion/comment/82185727#Comment_82185727

I appreciate the effort that has gone into gathering the FOI evidence, but I'm struggling to see what this enormous AI-generated essay actually adds to the discussion.

The central point is straightforward: the Government is introducing a statutory Code with promises of independent oversight, yet the existing ATAs will continue policing their own members during an undefined transition period. Meanwhile, the DVLA's FOI responses raise legitimate questions about whether the existing sanctions regime is functioning effectively.

That is a perfectly valid concern and one worth putting before MPs. Unfortunately, it has been buried beneath pages of repetitive commentary, unnecessary explanations and the sort of verbose, AI-generated prose that makes a relatively simple argument unnecessarily difficult to follow.

I don't think we're doing ourselves any favours by flooding the thread with lengthy AI output. The objective should be to identify the evidence, explain its significance and establish what action we want Parliament to take. That can be accomplished in a few concise paragraphs without subjecting everyone to an exercise in verbal incontinence.

I would respectfully suggest that if you want to create an AI generated story for possible publication, you should distill it enough that a news desk editor will want to actually use it with as little editing as possible. Here is an example of something that may be of interest to a journalist or reporter and explains the issue more concisely:

Private Parking Scandal: Is the Government About to Hand Control Back to the Industry It Promised to Regulate?

After seven years of delays, the withdrawal of the original 2022 Code and repeated concessions to the private parking industry, the Government is finally introducing statutory regulation. Yet the new Code retains the £100 parking charge, permits the controversial £70 debt recovery addition and leaves the existing trade associations and their supposedly independent appeals services largely intact.

For motorists, the danger is that the Government may be giving statutory credibility to a discredited enforcement system without adequately addressing the abuses that made regulation necessary in the first place.

The British Parking Association (BPA) and International Parking Community (IPC) have spent years policing their own members, while motorists face questionable charges, aggressive debt recovery demands and an endless stream of county court claims. The Government itself acknowledges that the existing system has suffered from inadequate independent oversight, inconsistent auditing and limited transparency.

Now comes the most alarming development. UKAS is inviting applications from organisations wishing to become certification bodies under the new statutory scheme. What safeguards will prevent the existing trade associations, or supposedly arm's-length organisations connected to them, from securing control of the very certification process intended to replace industry self-regulation?

If genuine independence is not guaranteed, motorists risk being left with the same operators, the same questionable appeals arrangements and the same financial pressure, merely operating beneath a new government-approved badge.

The consequences extend beyond individual parking charges. Motorists who refuse to pay disputed demands continue to face debt recovery threats and county court proceedings, placing further pressure on an already stretched justice system.

This is a critical moment for consumer protection. The Government has an opportunity to break the industry's influence over its own regulation, but unless the new certification and appeals arrangements are genuinely independent, years of promised reform could amount to little more than a change of letterhead.

The question Parliament should be asking is simple: is the Government finally regulating the private parking industry, or allowing the industry to regulate itself under statutory cover?