Forum Topics SPZ SPZ Industry

Pinned straw:

Added a month ago

At the recent $SPZ AGM, CEO Paul spoke about the latest round of Government consultation on the UK Code of Practice for Private Car Parking. Consultation completed in September 2025, and Paul indicated he expected a 3-4 month timeline for the Government to issue its response, which he expects would then lead to a further round of consultation.

In everything that follows in this Straw, it is important to recognise that $SPZ was key in shaping the existing, voluntary, industry-led Code of Practice, and that $SPZ aims to operate to the highest standards of compliance with this code.

Because of the importance of the UK market to the value of $SPZ, I have (with the help of my BA) undertaken a deep dive into what various UK consumer advoccay bodies have been publishing regarding their submissions to the consultation process.

Here are the key themes put forward by consumer advocates. Overall a common theme run through the consumer advovacy is a drive for a move from a voluntary code of practice, to a compulsory code with oversight and enforcement (i.e. Regulation).

1. Cap on Fines

  • Strong calls to reduce the standard parking charge cap to £50 for minor or routine cases.
  • Some support for retaining a £100 maximum only in the most serious cases, not as a default.
  • Emphasis that fines should be proportionate to the breach.

2. Ban or Limit Excessive Fees

  • Broad opposition to high debt recovery fees (e.g., £70 add-ons), viewed as punitive and unjustified.
  • Warnings that such fees damage trust and should be banned or significantly restricted.

3. Transparency and Data Reporting

  • Requests for mandatory publication of statistics on tickets, appeals, complaints, and cancellations.
  • Advocacy for full transparency to build accountability and public confidence.

4. Fair Appeals Process

  • Strong support for a single, independent appeals service to replace the current fragmented system.
  • Appeals should be accessible, impartial, and offer fair resolution, including clear rules for mitigating circumstances.
  • Recommendations that some types of tickets (e.g., minor keying errors or technical issues) should be automatically cancelled.

5. Oversight and Enforcement

  • Demand for a robust and independent scrutiny and oversight body with enforcement powers.
  • Suggestion that non-compliant operators should lose access to DVLA data.

6. Signage, Terms and Payment Clarity

  • Calls for better, clearer signage and communication of terms to prevent drivers from unwittingly breaching rules.
  • Emphasis on fair grace periods and allowances for minor or first-time mistakes.
  • Concerns about confusing or exclusionary payment systems (e.g., requiring smartphone apps or exact change).

7. Protection for Disabled Drivers

  • Support for strong enforcement against misuse of disabled bays.
  • Concern that weakening penalties could undermine accessibility protections.

8. Consumer Education and Rights

  • Proposals to include links to government guidance on parking rights in all notices sent to motorists.
  • Aim to empower consumers with information to navigate the system confidently.

9. Prompt Implementation of the Code

  • Frustration over delays in enacting the statutory Code of Practice despite it being legislated in 2019.
  • Urging swift action to stop widespread consumer harm caused by current practices.


The above points are a summary of a much more comprehensive body of research, including sources linked back to key consumer advocacy groups incl. AA, RAC, Which? etc.

What strikes me is the commonality of the themes being advocated across bodies. Clearly there has either been coordination among groups, or collective learning from the last time this process was run, or both. A push for £50 fines for "minor or routine cases" is a common theme.

While many of these points are likley to already be followed by $SPZ. Some, if adopted, could materially impact business performance. E.g., 1. and 2.

Over the next week we will gain some insight into how "on-the-nose" the Starmer Government is with voters, when they issue a pre-Christmas Budget, which is seeking to plug a hole in the public finances. There is a lot of sensitivity in the UK at the moment about cost of living, as they got hit a lot harder than we did in Australia by the post-pandemic inflation spike. (I had an opportunity to "sample" this during my European visit in June/July this year! Ouch.)

Equally, there is quite a high profile among the general public about the PBN process. As a personal, anecdotal data point, I've recently had a visitor from the UK staying with me, and she was quick to point out that her family are careful in keeping all their parking records, so that they can appeal when they get "unjustified penalities". It is something "top of mind" for them.

Importantly, from May next year there are a swath of local government elections, as well as elections for the Welsh and Scottish devolved governments and, at the moment, Reform is leading in the polls. Clearly, the Government will be keen not to do anything to further antagonise the electorate or even to offer some "wins" for "working people".

I will continue to monitor this issue as the next milestone will be when the Government issues its response to the consultation process.

It will be really interesting to get Paul Gillespie's take on this at the upcoming SM Meeting. How much of what consumer advocates are requesting is either already in the code of, if implemented, would not have a material impact? How likely does he think PBN values could be cut? Or, is the Government likely to follow what is likely to emerge in the Budget as freezing the fines for a period of years?

I don't have a view on any of this, other that I think the next few months is a key window in which we should be alert to regulatory risk in the UK. Afterall, we've seen what can happen in QLD and, to a lesser extent, in Denmark.

NewbieHK
Added a month ago

To add to @mikebrisy post I located this BBC article from earlier in the year.

https://www.bbc.com/news/articles/c4g2ej63dv1o

Although, it throws up possible challenges, I am also looking it at as a potential long term opportunity for SPZ. If the code comes in, a number of non-compliant (inefficient) operators may fold. This could allow SPZ to move in and make up any loss in value per PBN, with greater volumes. In addition, with a government endorsed code, they might put more effort into chasing up more of those unpaid fines.

From what I can see, the present private sector code developed from the two accredited trade associations called the British Parking Association (BPA) and International Parking Community (IPC), is basically a copy of the government proposed code but, with some of the more debatable (uncapped) fine systems in place.

This code was originally due to be implemented in 22/23 but, some of the private companies said they would take legal action. It’s quite possible that since then the Government has made policy changes. This will now enable them to implement the key aspects of what they want ie fine caps and as @mikebrisy has mentioned the climate is now right.

Below is a link to the consultation framework (closed)…

https://www.gov.uk/government/consultations/private-parking-code-of-practice/private-parking-code-of-practice

Below is a link to the code of practice developed by the private car operators associations (version 6 / 46 pages).

https://www.britishparking.co.uk/code-of-practice-and-compliance-monitoring

Anyway I found this all quite interesting.


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mikebrisy
Added a month ago

@NewbieHK good points!

I think we will see some change, and I believe we will see a mandatory code and regulation.

My reason is that 2025 marks the first time the UK has had a Labour Government since 1997. The previous Tory Governments had in their DNA a resistance towards introducing new industry controls, unless there was a compelling case. Car Parks never passed that hurdle.

With Labour, it is a very different story. Their entire platform is putting the interests of so-called "working people" at the front of the political agenda. With all the shonky, smaller car park operators in the UK, there is a public narrative that "Private Car Park Operators are the Enemy of Working People", and I think a well planned, Government response will be used to show that the UK Government is delivering on its election commitments, over which it has recently taken a real hammering, including today with stealth tax grabs in the budget announced today (yesterday).

So, my fear is whether the new regime comes with some headine-grabbing sound bite: "We will slash the GBP100 penalty levied by Private Car Park Operators to GBPXX".

Now that might be unlikely, because it could bring the Westminster Government into conflict with some Local Councils, as it will rally calls for Council charges to also be reduced, particularly in the large Metropolitan Boroughs, where fines can be as high as GBP130-160 (with 28-day payment discounts). Across the UK, many Local Councils are in financial distress. So, the last thing Westminster needs is to open warfare with some councils (increasingly Reform-controlled) over something as inconsequential as car parks, for which Westminster has no financial skin in the game.

As you say, a mandatory code with regulation and enforcement, might turn out to be a good thing for $SPZ, as it will make the industry less attractive to the shonky operators.

I'm only 50:50 for my call on this. While I am a bit of a political tragic, and try to keep plugged in to the UK scene (having lived there for 20+ years) I have no inside line on this, and am nothing more than an amateur political hack!

@Strawman it will be really good to have a good, in-depth discussion with Paul Gillespie on this in December. Depending how this swings it could be either very negative or mildly positive for $SPZ.

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lowway
Added a month ago

Some great info @mikebrisy with some good follow-up from @NewbieHK. I agree that there are some really solid queries in amongst this for the next SM meeting and (hopefully) Paul can offer some open and honest views about possible impacts on $SPZ or advantages they may gain by the possible tightening of regulation in this space.

I remain a holder IRL & SM portfolios

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Strawman
Added a month ago

Agreed -- some very good questions here, and I will put them to Paul next month.

I used my new AI assistant (recently switched to Gemini to see hw it compares to chatGPT) to distill the concerns raised into a series of questions.

Specifically;

Financial & Material Impact

  • Cap on Fines: What is the likelihood that the standard parking charge cap will be reduced to £50 for minor or routine cases, and how would this impact revenue?
  • Debt Recovery Fees: Is there a significant risk that debt recovery fees (e.g., £70 add-ons) will be banned or severely restricted, as demanded by consumer advocates?
  • Materiality: If the strictest consumer advocacy demands are adopted (capped fines and banned fees), what is the estimated material impact on SPZ’s business performance?


Operational & Compliance

  • Current Alignment: How much of the proposed mandatory code—such as grace periods, transparency reporting, and appeals processes—is Smart Parking already voluntarily complying with?
  • Appeals Process: How would the introduction of a single, independent appeals service and the potential for automatic cancellations of minor errors affect operational costs?


Strategic & Market Position

  • Consolidation Opportunity: If a stricter mandatory code forces inefficient or non-compliant operators to fold, is SPZ positioned to capture their market share and increase volumes?
  • Political Risk: Given the new UK Labour Government's focus on "working people" and cost-of-living pressures, do you view the regulatory risk as higher now than under the previous administration?
  • Timeline: What is the expected timeline for the Government's response to the consultation and the subsequent implementation of a statutory code?


Future Outlook

  • Valuation: How likely is it that the "value per PBN" (Parking Breach Notice) will be permanently cut under the new regime?


I'll add these to slido now so I dont forget.

[Disc. Held]

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