This study aims to analyze the provisions of Legal provision 36 paragraph (2) of Surabaya City Regulation Number 3 of 2018 concerning Parking Management, specifically regarding the legality and appropriateness of the application of administrative sanctions in the form of vehicle locking and a maximum fine of IDR 500,000 for parking violations, from the perspective of the principle of proportionality in state administrative law. This study uses normative legal methods with a statutory and conceptual approach. The results indicate that Legal provision 36, paragraph (2) formally meets the principle of legality because it is formulated based on legitimate authority and does not conflict with higher-level laws and regulations. However, in substance, the application of sanctions in this legal provision is deemed not to meet the principle of proportionality because it does not differentiate between levels of violations and does not provide an administrative objection mechanism for citizens. Therefore, implementing technical regulations and an evaluation of the substance of the norm are needed to ensure fair and balanced legal protection in the application of administrative sanctions in the parking sector.