Chief Executive’s Report, January 2025

Introduction

  1. The new year has arrived and with it, comes the launch of full operational oversight.

  2. In particular, it is really positive to have achieved our commitment to launch our complaints process on 6 January. We are now ready for whatever comes to the ECB through this new service and looking forward to getting going.

  3. It is also incredibly pleasing to have the new standards for Enforcement Agents come into force and to see Enforcement Firms starting to implement the firm standards, which come fully into force from April.

  4. Our work throughout last year was building up to the January launch of operational oversight and so it feels very significant to have reached this stage. That said, there remains a lot of important work for the ECB, and the whole sector, to do during 2025 to really make a tangible difference on our mission.

Financial management update

  1. The second round of levy collection is now complete. The process has been very smooth and we are on course to realise our projected income for the year once the licensing fees have all been collected. A staged payment agreement has been made with one firm and they have one payment still to make. While this does impact the ECB’s cashflow, it is not detrimental to our operation.

  2. The reforecast, approved at October’s Board meeting, has superseded the original budget and is now the target we are measuring actual expenditure against. Total expenditure for the year to 31 December 2024 is £858k against the reforecast of £871k, representing an underspend of £13k. Most of the larger budget line variances are due to phasing issues rather than over/underspend and we are expected to finish the year in line with the reforecast. As always, the budget is actively monitored and the Executive is confident that there are no areas of concern.

  3. The draft budget for 2025/26 will be presented at this Board meeting with the Draft Business Plan.

Staffing update

  1. Since the last Board meeting, we have welcomed our new Policy Manager into the team – Leonora Miles joined us on 13 January having previously worked at Macmillan on financial vulnerability policy. On 27 January we will also be joined by our new Director of External Affairs, Louise Rubin.

  2. We have also launched a recruitment campaign for a Risk and Compliance Principal who will lead the design of our oversight function. Applications for this role close in mid-February and we are looking to conduct interviews in early March. We had sought to secure a secondment for this role in the first instance but were unable to make this work.

  3. As set out in correspondence with the Board, the Director of Corporate Governance will be leaving the ECB in the Spring (she will be greatly missed) and we are seeking to bring in a replacement on an initial 12 month fixed term basis. We should be able to provide an update at the Board meeting on this.

Accreditation

  1. We have been advised that the last remaining High Court Enforcement group with any kind of scale that is not yet ECB accredited, is likely to apply for accreditation soon.

  2. The number of accredited in-house teams at Local Authorities remains, publicly, at seven – LB Merton, Wrexham, Flintshire, Anglia Revenues Partnership, Durham, LB Southwark and, just before Christmas, Conwy. We continue to encourage further application for accreditation, and we expect new interest following MHCLG’s publication of its latest Council Tax Information Letter on 9 January, which gave prominent support to accreditation.

ECB Standards Development

  1. Following publication of the standards for firms and agents, the standards for agents have now come fully into force. We have requested that all firms provide the ECB with a self-assessment of their compliance with the firm standards by 1 April. From this point, we will be fully using these standards in our determination of complaints.

  2. In the next few weeks, we will be publishing guidance to accompany the standards including guidance on reasonable belief, contracting and remuneration and engaging with third parties. This guidance has benefitted from input from members of our panel of industry experts and debt advice experts and has also been reviewed by the Board lead in this area and the Chair.

Complaints handling

  1. On 6 January our complaints system went live so we are now able to accept and process complaints about enforcement action that occurred after 1 January 2025.

  2. At the time of distribution of this report we are yet to receive any complaints and we expect it to be a couple of weeks before we receive any complaints we are able to make a determination on because of the requirement for firms to have considered the complaint in the first instance.

  3. We have also made progress on agreeing MoU’s with other relevant ombudsmen, we have had initial conversations with the LGSCO and will be meeting them in early February to agree terms. We have also contacted the relevant officials at the Public Services Ombudsman for Wales to set up a meeting to discuss the parameters of an MoU and have scheduled a date for the Ombudsman to meet the Chair in February. In addition to this, we have had preliminary discussions with the High Court Enforcement Officer’s Association to agree an MOU with them.

ICO Registration

  1. We have now registered with the ICO, as planned. The Director of Corporate Services is our Data Protection Officer. There is a separate item on the agenda in relation to ICO and data protection more generally.

Data Returns

  1. Following the presentation to the November Board of the aggregated results of the first, successful Data Return pilot (which will not be published), the second Data Return period opened on 1 January 2025 and will run until 30 June. The aggregated, anonymised results of this DR2 will be published later in 2025, while individual returns will for the first time be used internally by the ECB as evidence in its scrutiny and oversight work with firms. Minor changes have been to improve the DR form and guidance. For information, the revised documents are annexed in full to the Board papers.

Creditor engagement

  1. With the focus on Data Returns and the accreditation of local authority in-house teams we have been unable to give much focus recently to wider engagement with creditors. However, the Director of Creditors and Government will be considering a wider plan for engagement with the ECB’s new Director of External Affairs when she arrives at the end of January.

Communications and Engagement

  1. Until the new Director of External Affairs starts on 27 January, we are without specialist communications or public affairs support for a few weeks.

  2. We have kept up with all of our routine contributions to the trade press and maintained our social media presence. We also put out a low key package of communications activity around the launch of complaints handling on 6 January. We are planning to make a bigger push on public awareness of rights to complain later this year, once our systems have been tested with real cases.

  3. We are looking forward to the new Director of External Affairs joining and giving this area further attention and strategic focus for the coming months.

Political strategy and public affairs

  1. We have yet to receive a date for an introductory meeting with the new Courts and Legal Services Minister, following cancellation of the scheduled meeting with Heidi Alexander MP in December when she was appointed as Secretary of State for Transport. On 5 February the Chair and Chief Executive are meeting Luke Charters MP, a new Labour MP and formerly of the FCA, who has an interest in enforcement and whom we hope will be a useful advocate for ECB statutory powers.

Upcoming engagement

  1. Over the coming month, the team have the following engagements planned:
    • Attending a meeting of the Civil Justice Council working group on enforcement to consider a draft of its report
    • Meeting Luke Charters MP
    • Meeting the Public Services Ombudsman for Wales in Mid Glamorgan
    • Meeting with officials at the Local Government and Social Care Ombudsman
    • Further shadowing with High Court Enforcement Agents.

Linkedin-in
©2025 Enforcement Conduct Board
Linkedin