From London Heathrow to Manchester, Birmingham to Glasgow, drop-off and pick-up charges have become a common frustration for UK travellers. These fees — and the Parking Charge Notices (PCNs) that follow — are usually enforced by private parking operators such as APCOA, NCP, Vinci Park and others.
But there’s a tried and tested way to get many of these charges cancelled entirely. Known as the registered keeper defence, it’s a legal approach that works because most UK airport forecourts are not classed as “relevant land” under the Protection of Freedoms Act 2012 (PoFA).
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Why the Keeper-Only Strategy Works
Airport approach roads and forecourt areas usually fall under statutory control, governed by airport bylaws. This means:
- Parking operators cannot transfer liability from the driver to the registered keeper under PoFA.
- Only the driver can be pursued.
- The registered keeper is under no legal obligation to name the driver.
As long as the keeper does not admit to being the driver — and doesn’t name them — the parking operator’s case often collapses. Many motorists have won at both the initial appeal stage and later at POPLA (Parking on Private Land Appeals).
Example Appeal Text for UK Airports
Here’s an appeal letter you can adapt for any UK airport. Just replace the names in brackets with the correct details.
I am the registered keeper. [Parking Company] cannot hold a registered keeper liable for any alleged contravention on land that is under statutory control. As a matter of fact and law, [Parking Company] will be well aware that they cannot use the PoFA provisions because [Airport Name] Airport is not 'relevant land'.
If [Airport Name] 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 [Parking Company] is not the Airport owner and your ‘parking charge’ is not and never attempts to be a penalty. It is created for [Parking Company]’s own profit (as opposed to a bylaws penalty that goes to the public purse) and [Parking Company] 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. [Parking Company] have no hope at POPLA.
How to Use This Appeal
- Submit the appeal within the operator’s deadline (usually 28 days).
- Only write as the keeper — avoid identifying the driver.
- If rejected, escalate to POPLA using the same argument.
- Keep copies of all correspondence.
Airports Where This Has Worked
Motorists have successfully used this method at:
- London Heathrow – APCOA
- London Gatwick – APCOA/Vinci Park
- Manchester – APCOA
- Birmingham – NCP
- Stansted – APCOA
- Luton – APCOA
- Edinburgh – APCOA
- Glasgow – NCP
Final Tip
The key to success is never naming the driver and basing your argument on the fact that UK airport land is not “relevant land” under PoFA. This keeps liability firmly with the driver — and in most cases, the parking company has no realistic way to enforce the charge against the keeper.
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