Introduction
- Following our last Board meeting, it was excellent to launch our business plan for 2026/27 and the report on the consultation. We are now focussed on delivery of the important work that is set out in the plan.
- There has been a lot of external engagement in this period. Of particular note, were two well attended and constructive workshops with industry on our complaints process. This was an opportunity to feed back to industry on the themes we are seeing and potential areas of improvement and focus in first tier complaints handling. It was also a crucial opportunity to gain input into the scope and approach to our performance and efficiency review.
Financial management update
- The total expenditure at the one-month point in financial year i.e. to the end of April was £128,251 against the forecast budget of £140,405 giving an underspend against the reforecast budget of £12,154. The variances largely arise from phasing of certain budget lines and work is ongoing to phase these lines to smooth out any large variances.
- In terms of the balance sheet, the cash position as at the end of April was £283,367 (end March £441,107). Accounting for current liabilities, our net current asset position is £216,958.
- Based on our forecast expenditure for the current financial year, we hold 1.5 months of reserves based on the 2026/27 monthly run rate. However, in early May, following publication of the final business plan and budget 2026/27, we issued levy invoices to the top eight firms, amounting to £1.57m and expect the monies to start coming in towards the end of May and early June.
Annual report and accounts
- We propose to continue with the format of the annual report and accounts which we are required to file with Companies House by the end of July each year, but would expand the narrative to introduce more transparency – one of our five values. Industry responses to our Business Plan consultation consistently called for more transparency from the ECB, particularly in terms of how we use the levy and our outputs in each business year. Some of this information is already provided in our annual report and accounts but we think we could do more, building on the specific areas of concern raised by industry in the discussions we had with them during the business plan consultation earlier this year.
- The draft annual report and accounts 2025/26 will be presented to the Board at its July meeting for sign off.
Staffing update
- We held team days in London on 29 April and 20 May where we got to spend time with our two new team members, and had interesting presentations from the complaints team on some live cases in progress. We also held a leadership team day in London on 13 May, where we considered the work plan for the business year ahead.
Data Protection and IT update
- Our Managed IT Services providers, Elysian, have now completed five months of support for the ECB, having started on 1 December 2025. The helpdesk service continues to perform above expectations – the Director of Corporate Services met with the head of the helpdesk in May to review the latest rolling 3-month data.
Data protection update
- We have dealt with a number of Subject Access Requests (SARs) in the period since the last Board meeting, all of which arise from the complaints process. We have also been liaising with the complaints team on a GDPR matter relating to a complaint, where we took advice from the Information Commissioner’s Office. We can expect an increase in SARs over time, and acknowledge that some of them – as was the case for the ones dealt with in April – will be resource intensive.
Impact Reporting
- The Board has rightly expressed its desire for the ECB to develop its approach to monitoring and evaluating our impact in furthering our mission. This work is important because it will allow us to determine where and how we are making a difference and also help us to target future efforts.
- We have previously talked about introducing an Impact Report this summer to start this process. Having reflected more on this, we do not believe that we are currently in a position to do this in a meaningful way. At the moment we have a business plan focused on outputs. That has worked well as we are building the model and organisation, and our recent business plan consultation included an evaluation of achievements in delivering these outputs.
- We are now moving into the phase where we really need to be focused on evaluating the extent to which our work is delivering the right outcomes to support our mission. We are looking to move from delivering the outputs to measuring the impact of that work against our mission.
- We are therefore starting the process of building a proportionate impact evaluation framework. This will involve establishing the short and long term outcomes that sit below our mission, using a basic Theory of Change approach. Once we have agreed these, we will be able to establish what we would measure on each of these – some of which will already be available and some of which might require some additional evidence gathering.
- This leads us to the following plan:
- July Board – strategic session with Board on outcomes that sit underneath our mission.
- September Board – paper for Board on plan for starting to measure our impact in relation to the agreed outcomes, considering available data sources, gaps and plans to address these.
- October – the 2027/28 business planning process will begin and will be informed by the agreed outcomes and impact evaluation framework.
Oversight and Thematic Review
- As promised, the overall Thematic Review report on Fees, on which the Board saw a paper in March, was circulated to the Board in full out of committee. It has now been finalised and we are on course to publish it in early June.
- The publication of the Thematic Review report will pave the way for the ECB’s consultation paper on proposed new standards on fee charging. As that consultation paper will require some pre-working through with the industry, given the importance and controversy of fee-charging, we plan to complete the draft paper over the summer, and present it to the Board for clearance in September. Closer to that time, we can consider whether to then proceed with consultation then, or whether a short strategic pause would be favourable.
- All individual firm reports have now been issued. We are starting to receive confirmation of actions completed or further evidence from the firms involved as to how they are meeting the Standards and Regulations.
- As the Thematic Summary Report is now proceeding towards publication the main oversight activity has returned to building out the Risk and Oversight Framework. We plan to present a paper to the Board in July explaining our intended approach.
Complaints handling
- As of 19 May, we had 160 live cases. The cases are distributed as follows: 6 at Initial Consideration, 34 at Further Consideration and 120 at investigation stage.
- Of those at investigation, 16 are at draft decision stage, 14 are under investigation with the remainder (90) pooled for allocation.
- April was our busiest month yet in terms of incoming complaint numbers, with 106 complaints received.
- Notably, the number of open further consideration cases has reduced from 57 reported in my last update to 34. This has inevitably led to more investigations being launched but at a slower rate than before. We have completed 76 further consideration cases this business year and launched 38 investigations (50%). This represents a downward trend in the percentage of cases being passed for investigation. Part of the reason for that has been a focus on resolving complaints, identifying gaps in the complaint responses and referring them back to the enforcement firms to resolve; and a stricter focus on determining whether the complaint is more appropriate for the courts or the statutory complaints process.
- By 19 May we had received 157 complaints and closed 167. Those were closed as follows: 111 at Initial Consideration, 38 at Further Consideration and 18 at Investigation stage. Cases are allocated for further consideration and investigation outside of the relevant KPIs and so our performance against those targets is significantly compromised.
- Our performance against our KPIs is as follows:
| Complaint Stage | Target | Cases | Performance |
|---|---|---|---|
| Initial Consideration | Consider in 5 working days (from receipt) | 169 | 91% |
| Further Consideration | Consider in 15 working days (from receipt) | 76 | 3% |
| Investigation | Close in 90 calendar days (from Invest.) | 18 | 6% |
- In 60% of cases, we issued the decision whether to launch an investigation in 15 working days or less.
- We are now allocating cases for investigation that are just under four months from the date of the launch of the investigation. While far from ideal, the wait from launch to allocation has reduced from 5 and a half months to just under four. One of the key reasons for that has been a reduction in the case holding for each investigator so they can focus on completing the cases on hand. However, it is likely there will be slight reversal of this position over the next couple of months as the Complaints Manager moves to a reduced case holding and our new Investigator gets up to speed.
- We have closed 18 investigations so far this business year. This is lower than expected but reflects our reduced capacity in April. The investigation outcomes are set out in the table below.
| Investigation Outcome | Number |
|---|---|
| Not upheld | 11 |
| Partly upheld | 7 |
- Since my last report, we have received two decision review requests and have three in total that are under consideration. One of those is from an Enforcement Firm, which we have referred to one of our independent technical experts for consideration. We have also concluded two decision reviews and decided to look again at one complaint in the light of the additional explanation provided about the complainant’s circumstances. We have received a service complaint about delay, which we apologised for but explained that relevant updates had been provided.
- We also held two complaint workshops with industry. The focus of the workshops was to share the learning from the complaints process; seek ideas on their reporting requirements; and seek their feedback on the complaints process to inform the scope of the Process and Efficiency Review. The workshops generally went well and provide a useful basis for future engagement with industry.
Political strategy and public affairs
- The new session of Parliament began on 13 May and as anticipated the Government has not introduced a Bill to regulate the enforcement industry.
- We have appointed a public affairs agency – Red Rose – to help us build support and secure legislation this year.
Communications and Engagement
- We are continuing to build our stakeholder relationships and to that end have spoken at and attended a range of events over the past month. The CEO spoke at the BPA’s online forum on parking enforcement, providing an overview of our work to date and our plans for the coming year. Over 200 attendees were online and there were many questions from the floor, particularly in relation to enforcing road and traffic fines against vulnerable debtors. He also took part in a panel debate at the Vulnerability Registration Service Conference, which was well attended with delegates from regulatory bodies, enforcement, housing and fintech.
- The Director of Government & Risk was on the panel at the CIVEA Conference on 23 April, debating statutory regulation with representatives from enforcement, financial services and local government. He also attended the IRRV Spring Conference, at which CIVEA’s new President gave her first speech, and members of the team attended CAP’s 30 year anniversary event on 21 May.
- Further events are scheduled for June, including Money and Mental Health’s 10 year anniversary, the LACEF annual conference, and the HCEOA AGM.
- The final Business Plan was published on 5 May.
- Our Memorandum of Understanding with the Public Services Ombudsman for Wales was published in May and can be found on our website here: Memorandum of Understanding (MoU) between Enforcement Conduct Board (ECB) and Public Services Ombudsman for Wales (PSOW)
Organisational communications plan
- Scoping our work on building an impact evaluation framework has highlighted the need to revisit the overall plan and strategy behind our main outward facing comms products (for example, business plan consultation and publication, insight report, any future impact report, quarterly newsletters etc). This needs to include what each covers, how they sit together, who they are aimed at, and optimal timing for each. We plan to present an organisation communications plan/strategy to the Board in September, to cover this area, taking account of plans in relation to impact evaluation.