We were in London for our April Board meeting, which was focussed on forward planning.
We began by discussing responses to the ECB’s recent business plan and levy consultation.
The responses were broadly supportive about our direction of travel and the strategic priorities and activities that we had set out in our draft business plan.
The Board discussed the feedback received in relation to our strategic priority of engaging and influencing creditors and affirmed our view that this is an essential area of focus, given the central role that creditors play in setting the boundaries for how those experiencing enforcement are treated. Following the Institute of Revenues Rating & Valuation’s (IRRV) feedback, we agreed on the importance of providing more detail on what we propose to do in this regard, as well as engaging widely with a range of other creditors and creditor groups, including the Chartered Institute of Public Finance and Accountancy (CIPFA).
The Board approved our final business plan and agreed that we will be setting the levy for 2024/25 at 0.44% of turnover, a small increase on last year. We will soon publish our consultation report and final business plan.
The Board discussion then moved on to the communications and engagement plan that exits to support the delivery of our new business plan.
Having discussed 2024/25, we then moved on to some longer-term strategic thinking, through a workshop on the some of the external strategic drivers influencing our work and mission.
The workshop was based on work carried out by the team reflecting on our strengths and weaknesses as an organisation and the political, economic and social environment in which we are working. Some of the things we reflected on included:
- The likelihood that cost of living pressures will continue to bite
- The reported shortage of certified Enforcement Agents (EAs) and the interesting emerging findings from our workshops with them about what they like about their jobs
- The uptake of technology and the fact that there are already some interesting software solutions in existence which would be helpful for firms not least as we place a greater focus on identifying and dealing with vulnerability
- The importance of a wide range of evidence to inform and improve oversight, alongside the importance of not setting the evidential bar so high that it impedes the ECB’s ability to do its job
It was a wide ranging conversation and one which left us feeling that there are real opportunities on the horizon for the ECB to make a difference to our mission.
The next item on the agenda was a paper about the ongoing development of the ECB’s standards for enforcement work.
In particular, we discussed an early draft of how we might frame our new standards on vulnerability and affordability. These will be some of the most important and novel sections of our standards and so it is important that we get them right.
To that end, we have agreed that there will be significant future engagement on these areas, as well as implementation windows that reflect the desire to drive meaningful engagement, review and improvement from industry.
More generally, we agreed that our standards should be outcomes focussed, to set a clear bar whilst allowing space for industry to take ownership and innovate. However, we emphasised that it is important that they are also sufficiently clear to enable us to determine complaints consistently and, where necessary, to underpin effective enforcement.
The meeting ended with a thought-provoking session with Thinks Insights, who presented their interim research report. Thinks Insights have been running workshops with those who have lived experience of enforcement action and with Enforcement Agents and its clear that their research is going to provide us with insightful and useful evidence to factor into our ongoing work. We are expecting the full report in May and will ensure that we share the key findings over the summer, along with an explanation of how we intend to feed them into our work plans.
Several Board members had been out on enforcement visits since the last Board meeting and reflected on how useful that is in understanding the experience of those undergoing enforcement as well as those carrying it out – so many thanks to those who facilitated those visits.
Another useful Board meeting – with a lot of activity and engagement to look forward to over the next few months.