London’s busy airports — Heathrow, Gatwick, Stansted, Luton, and London City — all have one thing in common: high drop-off and pick-up fees enforced by private parking companies. At Heathrow and Gatwick, this is APCOA Parking; at other London airports, it may be different operators.
Many drivers find themselves receiving Parking Charge Notices (PCNs) after short stops, sometimes for just dropping someone off in the forecourt area. But a growing number are having these charges cancelled completely by using the registered keeper defence — without paying a penny.
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Why This Works at London Airports
The Protection of Freedoms Act 2012 (PoFA) allows parking firms to hold a registered keeper liable for a parking charge, but only if the alleged incident happened on “relevant land.” London’s airport forecourts and approach roads fall under airport bylaws, meaning the land is under statutory control and not classed as relevant land.
This means:
- APCOA (or other airport parking operators) cannot transfer liability from the driver to the keeper.
- Only the actual driver can be pursued.
- You are under no legal obligation to name the driver.
Because of this, appeals made strictly from the position of the registered keeper often succeed — either directly with the operator or later at POPLA (Parking on Private Land Appeals).
The Exact Appeal Text for London Heathrow & APCOA
Here’s the proven wording that has successfully had Heathrow 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 London Heathrow Airport is not 'relevant land'.
If London Heathrow 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.
How to Adapt for Other London Airports
To use this method at Gatwick, Stansted, Luton, or London City:
- Replace “London Heathrow Airport” with the name of the relevant airport.
- Replace “APCOA” with the correct parking operator (e.g., NCP, Vinci Park).
- Submit your appeal within the stated time limit (usually 28 days).
- Escalate to POPLA if rejected.
Steps to Appeal
- Appeal as the keeper only — avoid identifying the driver.
- Submit online via the parking company’s portal, or by post if required.
- If rejected, take it to POPLA using the same legal arguments.
- Keep records of all correspondence for your protection.
Final Tip
London airport forecourt PCNs can be beaten because of a gap in PoFA’s application to land under statutory control. Use the keeper-only defence, avoid naming the driver, and you stand a strong chance of having your charge cancelled without paying.
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