Chief Executive’s Report, October 2025

Introduction

1. We are now halfway through the financial year and it has been a very productive first half of the year:
   • We are now fully up and running on complaints and seeing the value of that process in providing redress to individuals and also targeting our oversight activities to ensure that lessons are learned and improvements made at firms following upheld complaints.
   • We are out for consultation on draft Vulnerability and Ability to Pay standards, which will complete our standards for firms and Enforcement Agents.
   • On oversight, we have conducted our first on-site audit of an enforcement firm and have started our wider thematic review on overcharging (which will see many more on-site visits).
   • We have developed our blueprint for statutory powers and are continuing to work with Ministry of Justice officials on next steps, following the Minister’s commitment to give the ECB statutory powers.
   • We have continued to grow our reach, including accrediting ten Local Authority teams.
     
     

2. It is from this foundation that we are now starting to look ahead at the strategic and operational focus for the next business year, of which the strategy session at this month’s Board meeting will be a key input. And, of course, alongside this, there remains a lot of important work to do over the next six months.
   
   

Financial management update

August management accounts – summary

3. Total expenditure for the first five months of the financial year i.e. to the end of August was £566k against a budget of £592k, giving a small underspend of £26k. The underspend continues to be related to phasing and timing of expenditure.
   
   

4. In terms of the balance sheet, the cash position as at the end of August was £888,749. Accounting for current liabilities, our net current asset position is £1.067m (last month – £1.196m); and total assets currently stand at £1.157m.
   
   

5. We have now concluded the reforecast process for the financial year 2025/26 and this is presented as a separate item on the agenda. This shows a small projected overspend against the original budget, which is largely accounted for by higher staff costs (we have had to resource a higher-than-expected volume of work on complaints, and more work on oversight activity in relation to overcharging review work).
   
   

6. We will be starting work on the 2026/27 budget shortly and will present the early draft numbers to Board in November.  
   
   

Staffing update

7. We held a successful team day in London on 24 September, where we had a morning ‘teach in’ on civil enforcement from an expert in the field as well as sessions on complaints, and strategy. Our next team session will be on 22 October. We will be seeking to schedule an expert ‘teach in’ on high court enforcement in the near future.
   
   

Data Protection and IT update

8. As previously reported, the Managed IT Services invitation to tender closed on 31 July and we met shortlisted companies in late August and early September to discuss the key elements of their submissions, including pricing. We have decided to move to a new supplier and are likely to make the switch on 1 December. While there are always risks in an IT switchover, we are confident that the new service provider will give us a high level of support. Their first piece of work will be for the new provider to undertake an audit of the current arrangements and we are likely to need Board members’ input to that. This will involve a review of the technology estate, and recommendations as to any remedial actions required. The Director of Corporate Services will keep in touch with Board members on the logistics of the transfer to the new provider.
   
   

9. We also issued an invitation to tender on website hosting and branding support which closed on 31 July. An update on the outcome of that tender is provided in the communications section below.  
   
   

10. There have been no significant data incidents since the last Board meeting.
    
    

Workplan and milestones for next 6 months

11. As we hit the half-way point of the financial year, we have recently reviewed the ECB’s workplan for the second half of the year and how it maps across to forthcoming Board meetings. This is reflected in the Board Forward Look.
    
    

12. There are two key points to note from this. Firstly, we are proposing to launch the ECB’s first Insight Report in January 2026, using the APPG on Financial Inclusion and Debt for an event to mark this. We had previously been discussing December but this was not possible for the APPG. We have taken the view that November is a little too soon and so opted for January, which should tie in well with other work such as the consultation on our next draft business plan.
    
    

13. Secondly, we are now proposing to finalise and launch standards on Vulnerability and Ability to Pay by the end of January, rather than December 2025. This is because we do not believe that the window between the consultation closing and the November Board meeting will provide sufficient time for analysis of responses and making any drafting changes that may be required. The timetable was always going to be tight and we ended up launching the consultation one week later than planned, as a result of the need to draft important new provisions on third parties, which makes it not workable.
    
    

14. Whilst it would be ideal to have the final standards launched by the end of 2025, as we have previously planned, it is also extremely important that we allow sufficient time to properly work through and analyse all responses received. These standards will shape practice for years to come and we believe that pushing back launch by one month, in the circumstances, will be well worth it. We are therefore now planning to bring the report on the consultation and final draft standards to the January Board for approval. I am happy to discuss this proposal and potential alternatives approaches, such as scheduling an extraordinary meeting of the Board in December, at the meeting.
    
    

Accreditation

15. We have just launched the annual process of applications for reaccreditation to the ECB, which will give firms accreditation until November 2026.  The updated register of accredited firms will go up on our website by the end of November 2025.  This process will also involve collection of the levy from all firms that have not yet paid the levy for this year.
    
    

Oversight and Thematic Review

16. In line with the Board Paper noted at the Board’s meeting in September, the Oversight Team are pursuing a wider industry Thematic Review on fee charging policy and practice. Data and policy responses have been requested from the first raft of firms they will be making site visits to during October.
    
    

17. The Oversight Team will provide more detailed progress reports for the Board’s November meeting.
    
    

ECB Standards Development

18. We have finalised our work on developing the proposed approach to vulnerability and ability to pay (VA2P) and now have a complete set of draft standards. Following feedback received from the Board at the September meeting, we have revised and updated key areas of the consultation paper including introducing a section setting out our thinking on the need for the Standards to offer some protections to potentially vulnerable third parties who become involved in the enforcement process.
    
    

19. We launched our public consultation on our website on Friday September 19^th. It will be open for a period of six weeks, closing on 31^st October. The consultation was also shared directly with all accredited firms and in-house teams, the Stakeholder Engagement Forum, Taking Control Coalition and a range of key stakeholders including creditors, the MoJ and HMT Government Debt Function.
    
    

20. To date we have received three responses and a range of stakeholders have signalled their intention to respond. We presented to the Taking Control Coalition on 30^th September, and they will be submitting a joint response. We will also be undertaking a series of engagement activities during the consultation period, including a structured in-person workshop on 23^rd October and drop-in sessions for industry, as well as meetings with wider stakeholders.
    
    

21. The research to test the key principles of the Standards with people with lived experience of enforcement and Enforcement Agents is now complete. A debrief session with the research company is scheduled for 9^th October.
    
    

Complaints handling

22. Our complaints casework continues to grow. As of 3 October, we had 102 live cases. They were distributed as follows: 7 at Initial Consideration, 20 at Further Consideration and 75 were at investigation stage.
    
    

23. Of those at investigation, 3 are at draft decision stage, 18 are under investigation with the remainder pooled for allocation. 
    
    

24. Incoming cases to the ECB have remained consistent since June and we are now receiving on average 20 to 25 cases per week. However, what has changed is the number of cases moving through to further consideration and then to investigation. 
    
    

25. We saw a significant jump in cases accepted for investigation in September.  The trend in cases accepted for investigation is as follows July – 18, August – 17, September – 36.  It is not clear at this stage if the increase in the accept rate for investigations in September represents a new trend.  However, as well as the obvious increase in the number of cases coming through to further consideration, part of the reason for the increase in the accept rate is having a dedicated member of the team managing and dealing with cases at the further consideration stage. 
    
    

26. By the end of September, the age profile of the further consideration cases has significantly improved, and we are looking for opportunities to develop the work at this stage further to better manage the flow of cases to investigation. 
    
    

27. Having a dedicated resource to manage the further consideration stage has enabled our investigation staff the space to focus on investigations.  With this model in place, we closed 16 investigation cases during September.
    
    

28. To date we have closed 415 cases, 337 at Initial Consideration, 40 at Further Consideration and 38 at Investigation stage. As expected, our performance against our KPIs has taken a bit of a hit.  We expect this to continue, as we make in-roads to cases that have been waiting attention, most significantly moving forward we expect our performance against our investigation cases to continue to decline until we can bolster our capacity in this area.
    
    

29. We are currently allocating cases for investigation at two months old and this presents a significant challenge in terms of closing investigation cases within the 90-calendar target (including sharing the decisions in draft first).  Our focus has remained on managing the expectations of the parties from the outset and providing regular updates.
    
    

30. We have met to discuss resourcing of the Complaints team and Board will be considering the immediate priorities as part of the reforecast paper today.   
    
    

31. 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. 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 12 cases. 
    
    

32. Since my last report, we have received four decision review requests.  We have considered and responded to two and found no basis on which to change our decision. We have not received any service complaints since the last Board meeting.
    
    

33. Our work to improve our case management system continues and this month our provider (Tizo) are finalising our first suite of reports.  These will provide quantitative and qualitative data about our performance and our findings.  We are also finalising arrangements for launching the demographic questionnaire and are aiming to start collecting that information from 1 November.
    
    

34. Our work with the Public Services Ombudsman Wales (PSOW) on the Memorandum of Understanding (MoU) continues.  We are expecting to receive their final comments on the draft MoU shortly. 
    
    

35. The Board will receive a paper on Complaints Trends and Analysis in November, which will go into further detail on the data and performance in this area.
    
    

Creditor engagement

36. Our engagement with creditors has primarily been in relation to the draft Standards, which were sent directly to all utility companies and several procurement organisations. Off the back of this several utilities creditors have agreed to meet with us in the coming weeks to discuss their approaches to vulnerability and ability to pay.
    
    

37. We are committed to developing a longer-range plan for engaging with and influencing creditors. We will be discussing this as part of the Board’s strategy workshop in October and hope to make further progress before the end of the year.
    
    

Political strategy and public affairs

38. In a meeting postponed from October, the Chair, CEO and Director of Policy and Oversight will be meeting Minister Sackman in November for further discussions on the Statutory Regulation consultation. We deal with the current state of play on MoJ’s consultation response and subsequent proposed Bill in the Board Paper on a future possible administrative model for the ECB.  In line with our Statutory Regulation Influencing Plan, we have begun to build a list of MPs with an interest in enforcement and contact them for meetings. This includes MPs who supported Luke Charters’ Private Member’s Bill and some who have tabled questions in Parliament. The Director of External Affairs has sent MPs our Blueprint for Statutory Regulation along with the meeting requests.
    
    

39. There have been several relevant developments in Parliament and in Welsh Government since the last Board meeting. In Wales, Government has confirmed changes to its council tax collection policies from next April: households will now have 63 days to address missed payments before enforcement can commence.
    
    

Communications and Engagement

40. Our communications in September and October focused primarily on the launch of the draft Standards, published on 19 September. We shared the draft Standards on social media, via our CEO Newsletter, and via an article in CIVEA’s Enforcement New, as well as sending them directly to stakeholders we’re particularly keen to hear from. Several stakeholders have shared the draft Standards in their own newsletters and social media posts, which will help us reach audiences we have less direct contact with such as individual debt advisers and enforcement agents.
    
    

41. We were also able to preview the Standards at September’s Stakeholder Engagement Forum and at the CIVEA Executive Council meeting.
    
    

42. We have shared news of our two new Board appointments via a press release and LinkedIn post.
    
    

43. We have continued to engage with the enforcement industry, with the Director of Policy and Oversight attending one firm’s Open Day in September where he presented and took Q&A on the work of the ECB from a gathering of clients, mainly from local authority enforcement.  Looking forward, the Director of Policy and Oversight is speaking at the Civil Court Users Association conference on 14 October, and several members of the team will attend the Money Advice Liaison Group conference (where the CEO is speaking) and the High Court Enforcement Officers Association luncheon in November.
    
    

44. As set out above, following discussions with the Leadership team and the Chair, we have taken the decision to delay the publication of our Insights Report to January 26, rather than November 2025. We have spoken to the Secretariat of the APPG Financial Inclusion and Debt and they are keen to help us launch the report at an event in Parliament in January. We are likely to hold a panel discussion with representation from debt advice and industry, as well as issuing a press release and related social media activity.
    
    

45. Engagement with our LinkedIn page is stable. We gained 31 new followers in September but engagement with our posts was slightly lower than previous months – likely because the Guardian article caused a significant spike in the summer months.
    
    

46. We have completed the tender process for our website and branding supplier. We received five bids, three of which were particularly strong. We have awarded the contract to a new supplier, who will commence work in November. While we are not looking to make substantial changes to our site or branding at this point, the new provider will support us to improve the website’s flow and to develop a social media strategy. We are looking forward to developing more engaging and more regular content in 2026.