It wasn't me driving
Someone else had the car — family, a friend, a buyer on a test drive. The charge still lands on the registered keeper's doormat. What you do next decides who, if anyone, is liable.
Phrases to look for on your letter: “as the registered keeper” · “the driver of the vehicle”
Why this is an appealable position
Private operators can pursue the DRIVER by contract, and the KEEPER only via POFA 2012 keeper liability — which demands strict notice timing and wording. You are not obliged to name the driver. If POFA conditions fail and the driver stays unidentified, liability can attach to no one. If you sold the vehicle before the event, liability is a matter for DVLA records: send the operator your date-of-sale evidence.
The clause to put in the letter
Name the paragraph, not just the rulebook. An operator answering "the Code requires a grace period" can wave it away; an operator answering its own clause number, quoted back at it, has to deal with what the clause says.
Code of Practice v1.1 §8.1.1(d): state the keeper is liable under the Protection of Freedoms Act 2012 where they cannot be held liable
(Design and language, page 20 of 57; read at source 2026-09-05)
PoFA 2012 Sch 4 para 9(2)(e): state that the creditor does not know both the name of the driver and a current address for service for the driver and invite the keeper
(Notice to keeper where no notice to driver was given; read at source 2026-09-05)
Code of Practice v1.1, Annex C, Table C note: Where the keeper fails to identify the driver (name and serviceable address) they will become liable after 28 days of the NTK. Unless the vehicle was stolen.
(Appeals and Liability, page 38 of 57; read at source 2026-09-05)
Your position is strongest when
- POFA notice windows or wording failed (see the late-letter page)
- Vehicle was sold before the event (V5C/DVLA confirmation)
- Vehicle or plate was stolen/cloned at the time (crime reference)
Evidence to gather now
- DVLA notification of sale / V5C new-keeper slip
- Crime reference for theft or cloning
- The NtK and its dates
Your first move
Respond as keeper only. Never name the driver casually — state the vehicle's status (sold/stolen/keeper-only response) and put the operator to proof of keeper liability.
Not sure yet? Check whether you'll lose your discount first — free
Build my appeal letter, freeAnswer 8 questions about what happened and get a ready-to-send appeal letter in minutes. It costs nothing, and you can download it.
The one thing on this site you can pay for is one operator’s full POPLA record, £20 once: three years of that company’s appendix rows, the grounds and the clause of its own rulebook that answers each one, its own published route and your clock. See what is in it, free. You never need it to appeal.
Common questions
Isn't refusing to name the driver dishonest?
No — it is a right Parliament deliberately preserved. POFA exists precisely because operators wanted keeper liability, and it comes with conditions they must meet.
Who issued your ticket?
Private operators and councils run entirely different appeal routes. Find your operator to see whether your independent appeal goes to POPLA or the IAS — or read the council PCN route if your letter says “Penalty Charge Notice”.
Still deciding whether it is worth it?
The question underneath this one is usually about money, not law: if I appeal and lose, does it cost me more than paying today? Check whether appealing puts your discount at risk — free, with the rule quoted from the code that applies to your issuer, and the published odds at independent appeal.
Where these rules come from: Protection of Freedoms Act 2012, Schedule 4 (keeper liability; the notice deadlines are its paragraphs 8 and 9) · British Parking Association · International Parking Community.