Fleet Vehicle KADOE Data — Operator Must Query DVLA for Keeper

When a private parking charge is issued to a fleet or lease vehicle, the operator can only hold the registered keeper liable under Schedule 4 of the Protection of Freedoms Act 2012 if it applied to the DVLA for the keeper's details for the date of the event (the KADOE route) within the strict statutory window and actually received that information (the 'third condition', paragraph 11). If the operator skipped the DVLA application, relied on other records, or ignored the lease company's hire paperwork identifying the hirer (paragraphs 13-14), keeper liability fails. Note: this defeats liability against the keeper only — the operator may still pursue whoever was driving, so never identify the driver.

Legal basis

PoFA 2012 Schedule 4 para 11 (the 'third condition' — creditor must have applied to the DVLA for the keeper's details within the para 8(4)/9(4) window and received them) and paras 13-14 (hire/lease vehicles); DVLA KADOE (Keeper At Date of Event) service — keeper-details applications made under regulations under s.22(1)(c) Vehicle Excise and Registration Act 1994

Sample appeal wording

Before you send this

Deadline. A late submission can be rejected without your argument being read. Check your notice for the deadline and how it is counted.
Paying may end it. Paying can count as accepting the notice and can close a challenge already under way. Part-paying or acknowledging an old debt can also revive a time limit that had expired.
The amount can change. Check what happens to the sum if you challenge — it may be held, re-offered lower, or keep rising, and fees or enforcement can continue meanwhile.
Use the official route. Use the method, recipient and form your notice specifies, with any reference, evidence and signature it asks for. Sent elsewhere, it may not count.
Only say what is true. Do not copy any statement of fact unless it is true for you, and check the legal point still applies. Delete what does not fit. It may be treated as your statement.
Careful what you volunteer. Avoid unnecessary admissions — naming the driver or accepting responsibility can remove arguments. But answer anything you are legally required to answer, and do include the evidence your ground needs.
Keep the record. Keep what you sent, the attachments, any receipt, and the reply. Note the next deadline.

Sample wording to adapt and send yourself — it may not fit your notice or the stage you are at.

The operator obtained KADOE data from the DVLA identifying the registered keeper as the lease company. The operator was on notice that this was a fleet vehicle and had an obligation to liaise with the lease company's fleet management arm to identify the driver before pursuing keeper liability.

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Fleet Vehicle KADOE Data — Operator Must Query DVLA for Keeper

Legal basis

Sample appeal wording

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