Introduction
- We are all set for a big start to 2026, with the launch of our first Insight Report in January being an early highlight. Putting out reliable, independent evidence on the enforcement sector has been a key priority for the Board and this will be a big moment in this regard.
- This will be followed in February with the consultation on our draft business plan and budget and the launch of our final Vulnerability standards, with publication of our report on the Thematic Review into overcharging not far behind this. We are therefore busy across the organisation preparing for all of this
- Alongside this work, we have recently welcomed two new members to the complaints team and it is fantastic to see the early difference that this is already starting to make to our capacity and ability to meet the ongoing high demand that we are seeing in this area.
Board Matters
- Delroy Corinaldi joined the Board with effect from the start of January 2026, and has completed an initial round of introductory meetings. Plans are in hand for Delroy to shadow an enforcement agent as part of the next stage of his onboarding.
Financial management update
October management accountsNovember management accounts – summary (oral update on December figures to be provided at the meeting, if available in time)– summary
- Total expenditure at the eight-month point in financial year i.e. to the end of November was £932,755 (October: £810,168) against the reforecast budget of £989,327 (October: £825,861), giving an underspend of £56,572 (October: £15,693). As last month, the underspend resulted from an underspend on salaries (owing to our figures on maternity leave pay being slightly out of kilter) and otherwise related to phasing and timing of expenditure (notable items: legal and recruitment).
- In terms of the balance sheet, the cash position as at the end of November was £827,441 (October: £859,760). Accounting for current liabilities, our net current asset position is £920,048 (October: £1,038,367).
- Based on the current underspend against the reforecast, we will close the financial year with carried forward funds of £330,363. Based on our reforecast expenditure, this equates to 2.6 months of reserves based on the 2025/26 monthly run rate (2.0 months of the 2026/27 monthly run rate).
- The draft business plan and budget 2026/27 for consultation is presented as a separate item on the agenda.
Staffing update
- We held a successful leadership team day in London on 10 December where the focus of the discussion was on resourcing for the remainder of the financial year, and budget planning for 2026/27.
- We held a team day in London on 17 December which comprised a morning session where we reflected back on the ECB’s achievements over the course of the calendar year, and an afternoon festive outing.
- A new team member joined us on 15 December to take up the post of Complaints Investigator, and we also welcomed a new Complaints Assessor on 2 January. Both are progressing very well with their onboarding. A further Complaints Investigator is due to start on 2 March[1]. All three candidates join from industry, and bring knowledge and experience of the complaints world within enforcement. More information on resourcing plans for 2026/27 are contained in the scoping paper for the business plan and budget 2026/27 later on the agenda.
[1] Update: This candidate has since withdrawn and so we are looking again for another Complaints Investigator.
Data Protection and IT update
- Our new Managed IT Services provider took over support for the ECB on 1 December 2025. They have now completed the initial phase of their audit of our IT estate, and the focus of the first stage of their work will be on making our IT infrastructure more secure. As previously reported, the Director of Corporate Services will keep in touch with Board members, should there be anything specific we need Board members to do.
- There have been no data incidents since the last Board meeting.
Accreditation
- The last CEO Report mentioned one small enforcement firm which had taken a conscious choice to withdraw from accreditation because of the cost when set against its small amount of TCOG enforcement work. We are seeking to bring the firm back in to accreditation, but the firm has so far not engaged on this. We hope to meet them in January, but this case highlights the need for statutory powers to make oversight mandatory to ensure consistent protection for the public and a level playing field for all firms.
Oversight and Thematic Review
- On the wider Thematic Review, the oversight team (comprising the Risk and Compliance Principal and the Director of Policy & Oversight) is on course to deliver a draft Thematic Report and recommendations to the Board in March, as scheduled. The Team has a final, short sprint of three firm visits to complete in January and early February, and then will finalise their analysis and interim conclusions in time to present the full report to the Board in March. The Director of Policy & Oversight can update the Board in Norwich should a fuller report be required.
ECB Standards Development
- The Board has a separate paper on the agenda outlining progress with our analysis of responses to last year’s consultation on draft Vulnerability and Ability to Pay standards. We remain on course for the final standards to be introduced early in 2026.
Complaints handling
- As of 11 January, we had 146 live cases. The increase in in-hand casework reflects the growing number of cases at the further consideration stage caused by the unexpected departure in November 2025 of the interim Enquiries Officer who undertook that work. The cases are distributed as follows: 10 at Initial Consideration, 59 at Further Consideration and 77 at investigation stage.
- Of those at investigation, 5 are at draft decision stage, 19 are under investigation with the remainder pooled for allocation.
- Incoming cases to the ECB had remained consistent between June and September, with between 80 to 100 cases being received per month. That has dropped slightly as follows: October 78, November 69 and December 79. We do not expect this small drop to continue but it has proven helpful in this period as we have been awaiting arrival of our new recruits.
- To date we have closed 618 cases, 492 at Initial Consideration, 58 at Further Consideration and 68 at Investigation stage. Given the higher than anticipated demand, resourcing challenges, a focus on training and inducting our two new starters (who joined on 15 December and 2 January) our performance against our KPIs is not where we would want it to be and is set out in the table below. The Board was alerted to these challenges when it discussed complaints data in November and the current position remains in line with what was discussed then.
- We are currently allocating cases for investigation at just under four months old, which is outside of our KPI of 90 calendar days. Our focus has remained on managing the expectations of the parties from the outset and providing regular updates.
- In terms of the cases awaiting further consideration, we have taken the same approach in terms of managing expectations and updating where necessary. The arrival of the Complaints Assessor on 2 January has already had an impact in terms of contacting the parties and moving cases forward. Of the 59 cases at further consideration 17 are being actively worked on. However, as we work through the old further consideration cases our performance against this KPI will decrease further.
| Complaint Stage | Target | Cases | Performance |
| Initial Consideration | Consider in 5 working days (from receipt) | 754 | 92% |
| Further Consideration | Consider in 15 working days (from receipt) | 262 | 71% |
| Investigation | Close in 90 calendar days (from Invest.) | 68* | 28% |
* One closed on basis complainant raising further linked issues with enforcement firm, which should be completed.
- Our investigations continue to demonstrate the value of the independent consideration of complaints, with over half having been either upheld in some way or resolved without the need for a formal investigation decision. The investigation outcomes are set out in the table below.
| Investigation Outcome | Number |
| Resolution achieved or offered after submission of complaint | 5 |
| Not upheld | 30 |
| Partly upheld | 23 |
| Upheld | 8 |
| Referred to body | 1 |
| Another scheme considering complaint | 1 |
- As well as providing remedies for the individual we have recommended changes to procedures and / or for reminders or training to be provided to staff in 24 cases.
- Since my last report, the MoU with the Public Services Ombudsman for Wales has been agreed and we are in the process of agreeing arrangements to publicise that.
Political strategy and public affairs
- We continue to encourage Government to publish its response to the statutory regulation consultation. At the time of writing there is no concrete information as to when this might happen but we remain hopeful that it will come early in the new year. We are meeting colleagues at the Ministry of Justice in January and will provide a verbal update at the Board meeting.
- The Director of External Affairs met with the Taking Control Coalition in late November to discuss the case for statutory regulation. Following that meeting the Coalition wrote to the Prime Minister, urging him to bring forward legislation as soon as possible (Post | Feed | LinkedIn). A letter to the PM was also sent from a cross-party group of MPs, led by Labour MP Chris Boore (Redditch MP rallies Prime Minister to introduce a statutory regulations for bailiff’s – The Redditch Standard). Both letters point to the ECB as the obvious choice for a statutory regulator.
- Our first Insights Report is on track for publication on 20 January, pulling together data from our oversights and complaints work and the industry data returns. The report provides us with a good opportunity to underline the case for legislation; we will send copies to the Prime Minister, Deputy Prime Minister and the Secretary of State for Housing, Communities and Local Government, as well as a wide list of other politicians and stakeholders.
- The All Partly Parliamentary Group (APPG) on Debt and Financial Inclusion will host a panel event on the Insights Report on 27 January, in Parliament. Russell Hamblin-Boone, CEO of CIVEA and Peter Tutton, Policy Director at StepChange will speak alongside the ECB’s Chair and Chief Executive. MPs and a range of enforcement industry and debt advice stakeholders have been invited.
- The Director of Policy & Oversight addressed the Civil Court Users Association Conference on 3 December about the benefits of ECB statutory powers, and will speak at a Conference for Local Authorities in London on 30 January.
Communications and Engagement
- Our communication and engagement work will focus on the Insights Report throughout January and February. We will share the report with stakeholders via Linked In posts and our CEO Newsletter, and it may secure some media coverage. Work is also underway to develop a communications plan for when we finalise our Vulnerability standards.
- We continue to engage with a wide range of stakeholders. In late November the Director of Policy and Oversight took part in a well-attended panel event organised by CIVEA, focusing on the ECB’s Vulnerability Standards and lessons we can learn from the financial services world. Several members of the ECB staff team also attended the HCEOA annual luncheon. We have a number of speaking engagement lined up for the first quarter of 2026, including conferences of the BPA, MALG, and the IRRV.
- The December Stakeholder Engagement Forum was well attended. As well as providing updates on ECB business, we sought feedback on our Know Your Rights guide. Attendees made a number of useful suggestions which we will follow up on in due course.
- We have published our Memorandum of Understanding (MOU) with the HCEOA. Work is now underway to finalise and publish our MOU with the Welsh Ombudsman.