Chief Executive’s Report, July 2025

Introduction

1. The Ministry of Justice’s announcement that it will legislate to give the ECB statutory powers, along with the associated consultation on how to do this, has been the main backdrop to the last month. It is really encouraging to see this clear statement of intent and heartening for it to have been accompanied by strong public endorsements from Ministers on the work that the ECB has been doing. This development has shaped much of our work this month and this will continue over the coming weeks as well.
   
2. But as this report shows, there has been significant activity across other areas of our programme as well, with our complaints caseload growing, our work on vulnerability and ability to pay progressing through the crucial external engagement stage and significant oversight activity in relation to identified breaches of standards and regulations on overcharging. These are all valuable opportunities to make a tangible difference in ensuring fairness for people who experiences enforcement action.

Financial management update
Levy

3. Virtually all levy payments have now been made, subject in some cases to an agreed payment plan, with a very small number of Local Authority in-house teams left to pay. The deadline was the end of June so we are chasing up those who remain.
   

Year end 2024/25

4. The Directors’ annual report together with the year-end financial position is set out in a separate paper on today’s agenda for the Board’s sign-off. We aim to submit our annual accounts to Companies House by the end of July.
   

May management accounts – summary

5. Total expenditure for the first two months of the financial year i.e. to the end of May was £190,857 against a budget of £221,031, giving an underspend of £30,174. The underspend is largely a consequence of phasing and timing of expenditure, as well as some invoices being received later than expected. This degree of underspend is expected to reduce month-by-month over the course of the year.
   
   
6. In terms of the balance sheet, the cash position as at the end of May was £849,133. This has risen significantly in the last month, as levy payments have come in. Accounting for current liabilities, our net current asset position is £1,442,768 (the total assets currently stand at £1,517,174).
   

Bank transfer

7. We received the news from Lloyds on 16 June that our application to open a new bank account was successful. The bank switchover from Co-op did not happen automatically in the end so we are in the process of transferring funds across to the new account.
   

Staffing update

8. Our new Complaints Manager, previously at Newlyn PLC, joined the ECB on 30 June as Complaints Manager. Our new Complaints Investigator (replacing our previous Investigator who has moved on to a new position outside of the ECB), previously at the Financial Ombudsman Service, joined us on 10 July.
   
   
9. We held a successful team development day in Manchester on 2 July, where we reflected on our busy work plan, and also did some team building work – the team has seen lots of news faces in recent months, and this time together was valuable and well spent.

Data Protection and IT update

10. We launched an IT contract invitation to tender on 7 July, where we are specifically looking for service provision to include standalone data protection and security provision. We are asking providers to include data resilience, business continuity, and security audits. The tender closes on 31 July. We are issuing an invitation to tender on website hosting and branding support at the same time, and will review responses to both tenders during August with a view to starting new services in the late summer, or early autumn.
    
    
11. There have been no significant data incidents since the last Board meeting.
    
    
12. We have dealt with one Subject Access Request in the period.

Accreditation

13. The Director of Policy & Oversight is visiting a Welsh in-house team on the morning of 16 July, before the Board meeting, to discuss their possible accreditation.
    

Oversight and Thematic Review

14. As the Board is aware, in the course of our oversight, the ECB has encountered some specific breaches of Regulation 11 of the Taking Control of Goods (Fees) Regulations and FS1.6 of the ECB’s Standards for Firms. This relates to failures to prevent charging of multiple enforcement fees, in circumstances where enforcement powers could reasonably have been exercised at the same time.
    
    
15. The issues that have been identified have been dealt with in line with our oversight framework. Comprehensive remediation plans have been put in place to provide refunds for people affected, independently investigate root causes and ensure implementation of appropriate measures to ensure prevention of future recurrence. We will monitor delivery of these plans closely.
    
    
16. To ensure that this sort of overcharging is not occurring more widely in the market, the ECB will be launching a Thematic Review into case linking and charging of multiple enforcement fees. This was agreed at the last Board meeting there is a scoping paper on this review on the agenda for the July Board meeting.
    
    
17. The CEO addressed the 2 July CIVEA Executive meeting about this issue and, on 3 July, wrote to all accredited firms to confirm that the Thematic Review will become the primary focus of ECB oversight activity for the remainder of the year. This will require the ECB to push back plans to do more general pilot monitoring visits, as set out in its Business Plan, which will now start in 2026.
    

ECB Standards Development

18. We have continued the early discussion process on vulnerability and ability to pay (VA2P) by holding targeted workshops with the advice sector and with selected small, medium and large firms to share the ECB’s initial thinking in this area and to get their input to inform the draft standards that we will launch for public consultation from September. The workshops were valuable, with challenge on a range of areas such as the proposed definition of vulnerability, on how agents would apply the standards in practice on the doorstep and on the impact of the ability to pay standards on the firms’ obligation to collect for creditors (including taking goods where necessary). At the same time there was many areas of common agreement, with a number of firms confident that they were already upholding much of the proposed new requirements and offering helpful points to develop them further.
    
    
19. Our overall conclusion is that the ECB’s early thinking is on the right lines but we will be reflecting on the lessons of the workshops in our drafting of instructions to lawyers to prepare the draft standards for September consultation. Before then, we will running a final workshop on 23 July for all firms that have not participated in a workshop so far. With this, all accredited firms will have had a chance to contribute before we consult on the draft standards from September.
    

Complaints handling

20. Our complaints casework is growing. As of 7 July, we have 73 live cases. They are distributed as follows: 20 at Initial Consideration, 10 awaiting Further Consideration, 10 at Further Consideration, 33 are at investigation stage. Of those at investigation, 5 are at draft decision stage. The remainder are awaiting allocation for investigation or in the process of being reallocated to our new investigators following the departure of the Complaints Investigator.
    
    
21. Incoming cases to the ECB have increased during June and we are now receiving approximately 20 cases per week (in the week commencing 30 June we received 23 new complaints). There has been a corresponding increase in the number of cases accepted for investigation. We accepted 9, 10 and 15 cases for investigation in April, May and June respectively.
    
    
22. The increase in incoming work represents a challenge for us as it coincided with the departure of the Complaints Investigator on 30 June (and her two-week annual leave at the beginning of June). To add to the challenge, we are approaching the summer period when members of the team have leave planned.
    
    
23. We have recruited new members to the Complaints Team, however the impact of their on-boarding will not be felt immediately, as they will go through an induction period and take a bit of time to get up to speed.
    
    
24. That means that the period from now until the end of August will be a significant pinch point for the Complaints Team. The focus during this time will be to progress complaints as far as possible and on managing the expectations of the parties and providing regular updates.
    
    
25. As we move into September and a steadier state, we will review again the format of the Complaints team, whether we require more capacity and at what stages of the process.
    
    
26. To date we have closed 194 cases. 170 at Initial Consideration, 14 at Further Consideration and 10 at Investigation stage. We are currently performing well in terms of our KPIs, set out in the table below. However, performance will dip during July and August.
    

Complain Stage	Target	Cases	Performance
Initial Consideration	Consider in 5 working days (from receipt)	223	97%
Further Consideration	Consider in 15 working days (from receipt)	47	91.5%
Investigation	Close in 90 calendar days (from Invest.)	10*	100%

*^{One closed on basis complainant raising further linked issues with enforcement firm, which should be completed.}

27. Since the last Board we have considered one decision review request (two in total) and found no basis on which to overturn our earlier decision.
    
    
28. We continue to work with our case management provider to improve the case management system and better manage our workload.
    
    
29. In terms of requesting and storing demographic information within the Tizo system, Tizo have made significant progress in developing a separate workflow for the information to be requested, received and stored securely. In the testing system there had been an issue in emailing the form and Tizo are currently working to resolve that. Once resolved it is possible to move forward with designing the demographic questionnaire and to issue it manually within the system. A manual approach will create extra tasks for the Complaints Team to complete so we are seeking to establish how we might get this automated within the system.
    
    
30. We have returned to Tizo about the further use of AI. They are undertaking research for us on the use of AI elsewhere in AWS cloud computing platform. This is in addition to the areas Tizo are currently looking to develop on:
    
    a) A vulnerability scanner that scans to look for key words that flag a potential vulnerability (this is currently being beta tested)
    
    b) Categorisation of data
    
    c) Allocation of casework
    
    
31. We met with the Public Services Ombudsman Wales (PSOW) on the Memorandum of Understanding (MoU) on 3 July and are in the process of finalising a further draft MoU in the light of that discussion.

Creditor engagement

32. We are developing a longer-range plan for engaging with and influencing creditors, and a paper on our approach for 2025/26 will be presented later in the year. This paper had been scheduled for July but we have pushed it back due to the need to prioritise responding to the MoJ consultation on statutory powers. The MoJ consultation in itself brings the ECB’s approach to creditors into consideration, so this will allow for our thinking to develop in this regard as well.
    
    
33. In the meantime, creditor engagement has been a big priority over the last 6 weeks: the CEO, Director of External Affairs and Director of Policy and Oversight presented at ten IRRV Forum events across England and Wales in June. We provided the Local Authority (and Enforcement industry) audience with an update on our work and held productive discussions on our upcoming vulnerability and ability to pay standards. We attended most of these workshops in person, facilitating good opportunities for discussion and engagement within and around the sessions.
    
    
34. We have also continued to build momentum with creditors on the parking and traffic management front, through meetings with TfL and Highways England and also speaking at events run by the British Parking Association. This has been helpful in bringing out parallels and also differences between enforcement of these cases and other types of civil enforcement.

Political strategy and public affairs

35. The Government published its consultation on regulation of the enforcement industry on 9 June. At a special meeting on 1 July, the Board considered its proposed response to the consultation. The Director of Policy and Oversight and the Director of Corporate Services have now drawn on the outcome of that meeting to prepare the ECB draft response to the consultation, which the Board is taking at its meeting on 16 July.
    
    
36. We had developed a Comms Plan in anticipation of the consultation launch, which is currently being implemented. As well as sharing the news on our social media channels and through our regular blogs and articles, we proactively sent out a press release and as a result, the consultation was reported on various BBC outlets, including on BBC Breakfast. Radio 4’s Money Box ran an in-depth piece on the topic, interviewing Minister Sarah Sackman as well as a person who has experienced poor enforcement practice. The ECB was referenced across all of the pieces.
    
    
37. Finally, HM Treasury has confirmed our place on the Government Debt Management Fairness Group, and offered us a number of places on the sub-groups that sit under that group. This places the ECB closer to policy-making on Government debt enforcement policy (while retaining our independence).

Communications and Engagement

38. June and July have been particularly busy months for communication and engagement. As well as attending the IRRV forums mentioned above, we:
    
    • Held meetings with StepChange and the Taking Control Coalition to discuss our provisional responses to the MOJ consultation;
    
    • Attended the Institute of Money Adviser conference, where the Director of Policy and Oversight took part in a panel debate on changes in enforcement
    
    • Held our regular meetings with the MOJ policy team
    
    • Met with the CEO of Money Advise Trust, Steve Vaid
    
    
39. We have produced articles and blogs for Enforcement News, the IRRV’s “Insights” magazine, the Institute of Money Adviser’s “Quarterly Account” magazine, and continued to increase our use of social media.
    
    
40. Engagement with our Linked In page is increasing. In June we gained 94 new followers – an increase of 394% from the previous month. Comments on our posts increased by 92% and reactions by 126%. Whilst our overall numbers are still relatively low, these figures are encouraging and demonstrate that interest in our work is growing.
    
    
41. We have closed our Twitter account in line with the Board’s decision and set up a new account on Blue Sky. As expected, engagement on Blue Sky is, so far, limited. This is in part due to it being a much newer platform with smaller numbers overall, but also due the ECB needing to invest more time in creating engaging content. We have now put out an Invitation to Tender, inviting brand, website and content specialists to contract with us when the current contract expires. The tender specifies that we are looking for support with creating more engaging content and we hope to roll this out from the Autumn.