Westminster City Council / Code 18
Westminster Code 18 PCN Appeal (2026)
Received a Code 18 PCN from Westminster? Code 18 concerns using a parking place to offer goods for sale. The council must identify the prohibited trading activity, not simply show that a commercial vehicle was parked.
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1. What does Westminster Code 18 mean?
A Code 18 PCN alleges that a vehicle was being used to expose or offer goods for sale in a parking place contrary to its conditions. The central question is what was actually being offered and how the vehicle was being used. A delivery vehicle, a trader visiting a customer and a vehicle being used as a sales stall are not the same situation.
- Contravention
- A Code 18 PCN alleges that a vehicle was being used to expose or offer goods for sale in a parking place contrary to its conditions
- Category
- On-Street Parking PCNs
- Issuing authority
- Westminster City Council
- Formal representation deadline
- 28 days beginning with service of the Notice to Owner or postal parking PCN.
- Penalty and discount
- Use the charge and discount printed on your PCN; the applicable amount depends on the notice and contravention date.
- Initial discount
- The initial 50% discount applies for 14 days beginning with PCN service, or 21 days for an approved-device postal parking PCN. An early challenge may lead to a renewed discount if rejected; check the council's policy and the amount and deadline in its reply.
- Appeal route
- Westminster, then London Tribunals after a formal Notice of Rejection.
2. What must Westminster establish?
Identify the parking place and read its conditions with the order provision relied on. A business name on a vehicle is not a traffic sign or proof of prohibited selling.
If the allegation concerns offering the vehicle itself for sale, check that precise activity against the order; do not assume every sales advertisement is treated identically.

- The parking-place order must prohibit the sales activity alleged at this location; Code 18 is not a general ban on commercial vehicles.
- The evidence must identify how goods were exposed or offered for sale from the vehicle, rather than rely only on branding or goods carried inside.
- Distinguish roadside selling from delivering an existing order or parking while working elsewhere.
- Any trading licence or written permission must cover the actual location and activity, including any separate parking authorisation required. Ordinary parking payment does not grant trading permission.
3. Grounds and exemptions for a Westminster Code 18 appeal
The statutory ground must match what happened. These code-specific points explain how to establish it.
Permission must cover the actual use of the vehicle and parking place. Normal parking payment or a resident permit does not automatically authorise trading. Where the council alleges that the vehicle itself was offered for sale, inspect the order and evidence of that particular allegation rather than assuming every sales advertisement is governed identically.
- The vehicle was delivering previously ordered goods rather than offering goods for sale from the space. Explain the order, destination and handover, with documents that distinguish the activity from roadside trading.
- The vehicle was simply parked while its user worked elsewhere. Ask the council to identify the sales activity it recorded rather than relying only on business branding or the presence of goods inside.
- The applicable parking order did not prohibit the activity alleged, or the PCN identifies the wrong place or period. Request the provision relied on and compare its wording with the officer's account.
- A street-trading licence or other written permission expressly covered this location and activity. Check whether separate parking permission was also required; a general trading licence does not necessarily override parking-place conditions.
- The alleged parking contravention did not happen, including where a relevant exemption applied or the restriction was not adequately signed.
- You were not the owner at the relevant time: you never owned the vehicle, sold it before the event or acquired it afterwards.
- The vehicle was under someone else's control without the owner's consent at the time of the alleged contravention.
- You are a vehicle-hire firm and the vehicle was hired under a qualifying agreement with a signed statement accepting PCN liability. Supply the hirer's name and address.
- The authority is demanding more than the penalty legally applicable to this case.
- The authority failed to comply with a statutory requirement in imposing or recovering the penalty: a procedural impropriety.
- The traffic order relied on is invalid, except an order subject to Part 6 of Schedule 9 to the Road Traffic Regulation Act 1984.
- For a postal PCN relying on prevented service or a qualifying drive-away under regulation 10(2)(b) or (c), nobody prevented the officer from attaching or handing over the PCN. This is not the ground for an approved-device postal PCN.
- The enforcement notice should not have been served because the penalty was already paid in full, or at the valid discounted amount by the applicable deadline. Paying a parking tariff is different from paying the penalty.
4. How to make a formal representation to Westminster
For a parking PCN attached to the vehicle or handed to the driver, send an informal challenge to Westminster. Formal representations are made against the Notice to Owner, or directly against a postal parking PCN, within 28 days beginning with service. Respond to the formal notice even if an earlier informal challenge is unanswered.
The initial 50% discount applies for 14 days beginning with PCN service, or 21 days for an approved-device postal parking PCN. An early challenge may lead to a renewed discount if rejected; check the council's policy and the amount and deadline in its reply.
Westminster's published parking-challenge principles require individual consideration, proportionality and assessment of relevant evidence. They allow discretion for sufficiently strong mitigation, including genuine mistakes or circumstances beyond the motorist's reasonable control; cancellation depends on the particular case.
- The officer's photographs of any stall, advertisement, goods or customer transaction.
- A prior order, delivery note or appointment record explaining the commercial visit.
- The trading licence or location-specific permission and its conditions.
- The parking-place order provision relied on, together with photographs identifying the space.
- Open Westminster's PCN service below. Enter the PCN reference and vehicle registration to find the notice and evidence.
- Enter the full PCN reference and vehicle registration. Westminster's portal accepts notices beginning WE, WM or WS. The council says photographs can take up to 24 hours after issue to appear.
- Use the challenge portal or send a written challenge to parkingappeals@westminster.gov.uk with the PCN number and vehicle registration. Do not use the general parking enquiry form to challenge a PCN.
- Westminster says the case remains on hold pending its response and an applicable discount is still offered after an unsuccessful challenge submitted during that discount period. Avoid repeat correspondence unless supplying additional information or evidence.
- Explain which part of the Code 18 allegation you dispute. Include the PCN reference, vehicle registration, your address and copies of photographs or records supporting each point.
- Save the full submission, attachments and dated acknowledgement.
5. How long does Westminster have to respond?
Westminster must serve its decision within 56 days beginning with receipt of qualifying formal representations. If it fails to comply, those representations are deemed accepted. This statutory period applies to formal representations, not an informal challenge or a request for photographs.
[6]6. If Westminster rejects your representation
A formal Notice of Rejection explains Westminster's decision and how to appeal to London Tribunals. You have 28 days beginning with service of that notice to pay or register your tribunal appeal.
Compare the reply with the Code 18 grounds and evidence you submitted. Identify any unanswered point, missing evidence or inconsistency between the restriction and the recorded event. Keep the rejection notice and the appeal details supplied with it.
An informal rejection is different: formal representations can be made if a Notice to Owner follows.
[6][7]7. Taking your Westminster appeal to London Tribunals
London Tribunals is independent of Westminster. Use the registration instructions and verification details in the Notice of Rejection, upload your evidence and explain why the alleged Code 18 contravention or liability is disputed.
There is no fee to register the appeal. If it is refused, the full penalty is normally payable; an earlier discount does not automatically continue. If registering late, explain the delay so the adjudicator can decide whether to accept the appeal.
Read Westminster's evidence pack and respond to the points relevant to your case. Keep to the tribunal's directions and evidence deadlines.
[6][10]Tribunal examples relevant to Code 18
These London Tribunals decisions illustrate issues relevant to Code 18. They involve the authorities named below, not necessarily Westminster. Use the reasoning that matches your evidence; these are not Westminster-specific outcomes.
An order and maps did not prove the alleged parking event
Case 2250022866 / 2025-05-01 / Adjudicator Belinda Pearce
Belinda Pearce allowed the appeal because the authority had not supplied evidence substantiating the alleged contravention. The parking order and plans did not establish what the vehicle was doing at the relevant time.
Read the case commentary“In the absence of evidence to substantiate the assertion I can find no contravention proved.”
Belinda Pearce, case 2250022866
2025 London Tribunals results: shared context
4,151 of 13,391 recorded cases were allowed (31.0%).
| Recorded outcome | Cases |
|---|---|
| Allowed | 4,151 |
| Refused | 9,240 |
| Total | 13,391 |
Full Code 18 PCN Appeal Guide
Read the detailed legislation, signage requirements, exemptions and case analysis for this contravention.
Read the full Code 18 PCN Appeal GuideSources and references
- PATROL: Contravention codes and suffixes
Contravention codes and suffixes
- Department for Transport: On-street parking control signs and road markings
On-street parking control signs and road markings
- Department for Transport: Statutory guidance on civil parking enforcement in England
Statutory guidance on civil parking enforcement in England
- London Tribunals: grounds of appeal for parking
Nine parking grounds. Read with SI 2022/576 regulation 5 for the hire, traffic-order, postal-service and already-paid conditions.
- England's 2022 parking representation requirements
Regulation 5(2), (4)-(8): grounds, compelling reasons, ownership and hire particulars. Regulation 4 limits the postal-PCN route to an unpaid penalty; regulation 3 distinguishes informal challenges and formal notices.
- England's statutory deadline for deciding formal representations
Regulation 6(2)-(7): late representations, consideration of evidence, decision service within 56 days of receipt, rejection requirements and deemed acceptance.
- England's independent parking appeal requirements
Regulation 7(1)-(8): 28 days beginning with rejection service, adjudicator's power to allow more time, appeal outcomes and recommendations on compelling reasons.
- England's 2022 parking notice and service rules
Regulation 2 defines the applicable discount date; regulations 9-11 govern vehicle and postal PCNs; regulation 20 covers the Notice to Owner; regulations 21-23 cover later recovery. Schedule 2 specifies notice contents.
- DfT: statutory guidance on civil parking enforcement in England
Collecting penalty charges; informal challenges; formal representations; notification of outcomes; adjudication. Distinguishes statutory duties, discount re-offer guidance and discretion.
- London Tribunals: preparing your appeal
Registering an appeal, verification details and supporting evidence.
- Westminster: challenge your parking ticket
How to challenge your parking ticket; We'll show you; You'll need; Challenge now link; written challenge email; general enquiry restriction
- Westminster: view evidence, pay or challenge a PCN
WE, WS and WM prefix instructions; ticket reference and vehicle registration fields; linked by the council's Challenge now button
- Westminster: consideration of parking ticket challenges
Consideration principles; Merits of the case; Genuine mistakes, mitigation and discretion; Proportionality; Full consideration of evidence
About Parking Mate UK
For Code 18, we focus on offering goods for sale from a parking place: the restriction at the location, the evidence recorded and the ground that answers the allegation. We use relevant London Tribunals decisions to help identify what makes that evidence persuasive.
The 2025 London-wide analysis above covers 13,391 decisions: 4,151 allowed and 9,240 refused. Its stated category scope applies; these are not Westminster-only figures.
Send us your Westminster Code 18 PCN for a free assessment. Parking Mate UK prepares and submits your formal representation to Westminster and handles your London Tribunals appeal, with support online and on WhatsApp.
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