Drivers using Manchester Airport are no strangers to high drop-off and pick-up fees — and the parking charge notices (PCNs) that often follow. Operated by APCOA Parking, the airport’s forecourt and drop-off zones are heavily monitored, with cameras recording every vehicle entering and leaving.
But a growing number of motorists are getting these charges cancelled entirely by using a simple but powerful legal argument: appealing as the registered keeper without naming the driver.
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Why This Works at Manchester Airport
The Protection of Freedoms Act 2012 (PoFA) allows parking companies to transfer liability from the driver to the registered keeper — but only if the alleged contravention happened on “relevant land.” Manchester Airport’s roads and forecourts fall under airport bylaws, meaning the land is under statutory control and is not classed as relevant land.
This distinction is crucial because:
- APCOA cannot transfer liability to the keeper under PoFA.
- They can only pursue the actual driver.
- There is no legal obligation for the keeper to name the driver.
If you appeal in the right way, sticking strictly to your position as the keeper, APCOA often cancels the charge — either at the first stage or after escalation to POPLA (Parking on Private Land Appeals).
The Exact Appeal Text for Manchester Airport & APCOA
Here’s a proven appeal that has successfully had Manchester Airport APCOA PCNs cancelled:
I am the registered keeper. APCOA cannot hold a registered keeper liable for any alleged contravention on land that is under statutory control. As a matter of fact and law, APCOA will be well aware that they cannot use the PoFA provisions because Manchester Airport is not 'relevant land'.
If Manchester Airport wanted to hold owners or keepers liable under Airport Bylaws, that would be within the landowner’s gift and another matter entirely. However, not only is that not pleaded, it is also not legally possible because APCOA is not the Airport owner and your ‘parking charge’ is not and never attempts to be a penalty. It is created for APCOA’s own profit (as opposed to a bylaws penalty that goes to the public purse) and APCOA has relied on contract law allegations of breach against the driver only.
The registered keeper cannot be presumed or inferred to have been the driver, nor pursued under some twisted interpretation of the law of agency. Your Notice to Keeper can only hold the driver liable. APCOA have no hope at POPLA.
Works at Other UK Airports Too
While this exact version is for Manchester Airport and APCOA, the same legal principle applies to many other UK airports with drop-off and pick-up PCNs.
To use it elsewhere, simply:
- Replace “Manchester Airport” with the relevant airport’s name.
- Replace “APCOA” with the parking operator (e.g., NCP, Vinci Park).
Airports where this strategy has also worked include Heathrow, Gatwick, Birmingham, Luton, Stansted, Edinburgh, and Glasgow.
How to Use the Appeal
- Submit your appeal to APCOA within 28 days of the notice — either online or by post.
- Never identify the driver — keep the appeal strictly from the perspective of the registered keeper.
- If rejected, escalate to POPLA within 28 days using the same legal reasoning.
- Keep all correspondence for your records.
Final Tip
This method works because the law prevents APCOA from pursuing keepers for contraventions at Manchester Airport — unless the driver is named. As long as you stick to this position, you stand a strong chance of having the charge cancelled without paying a penny.
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