Station Car Park - APCOA fine

shundeez

I parked at Tonbridge station in September. I always pay via the APCOA app while on the train into work. I do this daily.

On this particular day the app was not accepting my payment details, I kept getting thrown out at the point of payment. Nothing wrong with the payment card as have been using it before and after this.

I get a fine from APCOA 9 days later.

Is there a chance I can appeal this and win, or let it time out. I believe the laws have been changed and cannot appeal by not naming the driver, or wait for the fine to time out after 6 months.

• The Law Changed in 2025: As of late December 2025, railway station car parks in England and Wales were reclassified and are now legally treated as "relevant land" under Schedule 4 of the Protection of Freedoms Act (POFA) 2012.
• Keeper Liability Now Applies: Because of this legal amendment, parking operators like APCOA can now legally recover unpaid parking charges directly from the registered keeper of the vehicle, regardless of whether you identify the driver. The old loophole of appealing as the keeper and staying silent is officially closed for any tickets issued after this date.
• The 6-Month Expiry Does Not Apply: By shifting these cases to civil POFA claims, the 6-month time limit for criminal byelaw prosecution no longer applies. It is now treated as a civil contract debt, which carries a 6-year limitation period.

Gr1pr

Definitely Not a fine, read it again

It doesn't time out after 6 months, but is statute barred after 6 years ( Limitations Act 1980. )

It should be a private Parking Charge Notice ( PCN. ) from Apcoa , an invoice

Check if it FULLY COMPLIES with POFA 2012 or not, timescales and wording

It definitely CAN be appealed by the Registered Keeper

cooldude255220

Without seeing the the PCN we cannot comment on any potential POFA arguments.

But you could try this:

It is understood that APCOA's authority to operate at Tonbridge Station is governed by its agreement with London & South Eastern Railway Limited (agreement number BSS03.1090) ("the agreement").

Page 103 of the agreement specifies that "Tonbridge" is one of the sites in the List of Sites (Schedule 6) to which the agreement applies.

Page 39 of the Agreement states:

2.3. Patrollers shall, on their patrol … 2.3.3. issue Penalty Notices in accordance with Bye Laws;

Page 53 of the Agreement states:
2.1. The Supplier’s Patrollers shall issue Penalty Notices (PN) for infringements in accordance with the Railway Byelaws.

Page 7 defines "Penalty Notice/PN" as meaning "a document placed on a vehicle, or sent by post to the registered keeper or hirer of a vehicle, requiring payment of a penalty, the liability for which has arisen due to a breach of the Byelaws".

This definition is clear: a penalty notice must arise from a breach of the Byelaws.

For the avoidance of doubt, the agreement does not permit APCOA to issue Parking Charge Notices for contractual breaches which do not arise from a breach of the byelaws.

APCOA have however issued a Parking Charge Notice, which alleges a "breach of the terms and conditions of use".

APCOA have no authority to issue Parking Charge Notices on the land in question. The PCN is therefore ultra vires and therefore this appeal must be allowed.