Grace period not honoured — BPA/IPC Code minimum

The BPA Approved Operator Scheme Code of Practice (Section 13) and the IPC Accredited Operator Scheme Code (Part E, Section 15) require a minimum 'consideration period' (typically 5 minutes) for the driver to read signage and decide whether to park, AND a 'grace period' (typically 10 minutes) at end of paid time to allow exit. ANPR durations include the time entering, finding a space, walking back to pay, and walking back to exit — so 'overstay' of a few minutes is often within the grace period. Operators who issue PCNs for small overstays under 11-15 minutes are likely in breach of their own AOS Code, which is enforceable as part of the BPA/IPC self-regulatory framework AND admissible to show unfairness under CRA 2015 s.62.

Legal basis

BPA AOS Code of Practice Section 13 (consideration and grace periods); IPC Code Part E Section 15; Consumer Rights Act 2015 s.62 (unfairness); ParkingEye v Beavis [2015] UKSC 67 (industry codes relevant to legitimate interest assessment)

How to identify this in your case

Overstay alleged is under 15 minutes; ANPR-based duration; consideration/grace periods not deducted from total stay.

Sample appeal wording

Dear [OPERATOR], Re: PCN [REF] — Alleged overstay of [X] minutes The alleged overstay falls within the consideration and grace periods that you are bound to observe under [BPA AOS Code Section 13 / IPC Code Part E Section 15]: - Consideration period: 5 minutes minimum on entry to read signage and decide; - Grace period: 10 minutes minimum at end of paid/permitted time before a charge may issue. Accordingly, an apparent stay of (say) 1h 14m where 1h was paid is within tolerance and no charge should have been issued. Further: 1. Issuing a PCN in breach of your AOS Code is a matter for your trade body. I will refer the breach to [BPA / IPC] and to the DVLA KADOE Compliance Team. 2. The term purportedly authorising the charge is unfair under section 62 Consumer Rights Act 2015 because, contrary to the requirement of good faith, it imposes a disproportionate sum where the overstay is de minimis and within industry-mandated grace. 3. The Beavis test ([2015] UKSC 67) requires a 'legitimate interest' proportionate to the charge. Charging for a few minutes within grace is not commensurate. The charge is denied. Cancel within 14 days. Yours faithfully, [NAME]

Replace [PARKING DATE], [NtK DATE] etc. with your own dates before sending.

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Sources

BPA AOS Code Section 13
IPC Code Part E Section 15
CRA 2015 s.62
ParkingEye v Beavis [2015] UKSC 67