Our September Board meeting fell less than a week after the Government’s announcement that it will make it mandatory for all enforcement undertaken by private companies to be under the ECB’s oversight.
We are very pleased that the Government has now committed to act. Over the last four years, with input from a wide range of people across the enforcement, debt and creditor sectors, we’ve proven the value of proper independent oversight in this important area.
We’ve built a small but highly skilled team that has delivered stretching new standards, an independent complaints service that has already handled over 1.5k complaints from members of the public, and a monitoring and compliance function to identify and put right poor practice.
But our work to date has also underlined the need for Government to act – to close the loophole that has allowed some companies to escape oversight.
The Government announcement makes clear that this loophole will soon be closed. When the legislation comes into force, we’ll have oversight of all relevant enforcement work and we’ll be able to provide proper protection for everyone who experiences enforcement action. It will also mean that no one can walk away from our oversight without leaving the market altogether, securing the long-term future of independent oversight.
There is work to be done over the coming months, with the MoJ, to prepare for taking on this expanded role and pushing to ensure that it also covers inhouse teams at Local Authorities. However, these changes are mainly about scale and coverage rather than requiring substantially different approaches. So we will be seeking swift introduction and implementation of the legislation.
For those already under our oversight, this is unlikely to lead to significant changes to how they experience our oversight. But it will mean a more level playing field, where all firms are held to the same standards.
The main scheduled item on the agenda for this meeting was a discussion of strategic communications priorities for the next 12-18 months.
We agreed a plan for a new rhythm of annual outputs, that will include our Insight Report, a new Impact report and regular newsletters that will include regulatory updates, case studies and good practice examples.
Our discussion then focused on the extent to which the ECB wants to communicate direct to people experiencing enforcement. The Board was clear that we are not best placed to do this and it would not represent good value for money for us to invest in general public awareness campaigns. But we agreed that there is more that we can do, in conjunction with those who are well placed to speak direct to people experiencing enforcement (such as debt advisors and the enforcement industry), to get key messages across to the public when they need to hear them.
Our role gives us unique insights and perspectives on what good and fair enforcement looks like and we also want to ensure that if people are treated unfairly, they know how to complain to the ECB. So we’ll be focussing on additional steps that we can take, working with colleagues across debt advice and the industry, to ensure that people receive good and reliable information about what to expect from enforcement action and what they can do if they do not believe they have been treated fairly.
We also agreed that for 2027/28 we will plan to do some work to overhaul our website. The core architecture for this was set up in a very different phase of the ECB’s development and now that we are fully operational, the time has come to revisit the way that it is structured, to improve accessibility for those who use it. We’ll be developing the plan for this work as part of our draft business plan for 2027/28, which we will be consulting on in early 2027.
Across the meeting, the Board also reflected on the significant outward engagement that the team has been undertaking over the summer, on the vulnerability guidance, the process and efficiency review of our complaints function, and new fees guidance and standards. It was encouraging to hear reflections from these engagements, including from a Board member who had been directly involved, and the constructive and valuable nature of the inputs we have received.
Our next meeting comes in early October. It will be held in London and we’ll also be welcoming CIVEA for a discussion with the Board.