Introduction
- We have started the new business year with operational oversight really starting to take off – we are seeing complaint numbers steadily increasing as firms transition to their new complaints processes. and the deadline for self-assessments of compliance with our standards at the end of April. Alongside this, our work on the vulnerability and ability to pay standards is ramping up as we prepare to start engagement on our starting proposals in these areas.
Financial management update
- April marks the start of the new financial year and a new round of levy collection. The 2024/25 levy collection process was efficient and effective with the ECB successfully realising its projected income for the year. The new round of levy collection, starting with the largest firms, will begin next month and we expect to complete this first round by the end of June (subject to any agreed payment plans).
- Total expenditure for the year to 31 March 2025 was £1.17m against the reforecast of £1.21m, representing an underspend of approximately £37k although this will be reduced after the accruals process is complete (predicted to be somewhere around £10-15k).
- Any operating surplus after the accruals process can be considered as moved to strategic reserves although, as discussed at previous Board meetings, the amount is likely to be very small, if anything.
- The final budget for 2025/26 was approved by the Board in March. From the June meeting, spend will be reported against the new budget.
Staffing update
- David Parkin has now taken on the role of Director of Policy and Oversight as maternity cover for Hannah Semple.
- Our new Risk and Compliance Principle arrives on 1st May and she will lead the design of our oversight function, working with David. One of her initial tasks will be to consider the Standards Self-Assessment Frameworks each accredited firm and council is submitting for 30 April, which will be one of the pieces of evidence we will use to guide our selection of oversight visits later in the year.
- Holly Perry, our new Director of Corporate Services has now joined us, and we will be saying goodbye to Jenny Prior who after two years in post, is attending her last Board meeting.
Data Protection Update
- We continue to make good progress against the Data Protection Implementation Plan presented to the Board in January.
- Our new Director of Corporate Services will be registering as the ECB’s new Data Protection Officer as soon possible.
Accreditation
- We are likely to receive applications soon for accreditation from two small civil firms. In the last CEO report we advised that the last remaining High Court Enforcement group with any kind of scale is likely to apply for accreditation soon. This has not yet materialised and we will reach out soon if nothing comes through.
- The Director of Policy and Oversight has recently had discussions with a small enforcement firm in the West Country, with the result that we are likely to offer them accreditation by the end of April. It will bring to 45 the number of firms accredited to the ECB (plus 9 in-house teams).
ECB Standards Development
- We are currently developing a draft discussion paper on standards for Vulnerability and Ability to Pay for discussion and sign-off at the June Board. We plan some early soft consultation on the draft discussion paper with trusted industry and advice sector figures in early May, and will use their comments to strengthen the paper before it goes to the Board. Once agreed by the Board we will use it for wider informal consultation and engagement in June.
- The date of the Board, 30 April, is the deadline for all accredited firms and in-house teams to have submitted their Self-Assessments of compliance with ECB standards. Their responses will be used to establish a comprehensive view of the level of compliance across the industry and to identify individual areas of risk and concern to shape ECB operations oversight. The Director of Policy & Oversight will update the Board on the performance of firms and councils in responding to the 30 April deadline.
Complaints handling
- Early trend analysis and an update on the implementation of the complaints process (up to 11 April) is provided in the Board papers.
- As of 22 April, we have 18 live cases, one is at initial consideration stage (where we ask can we investigate the complaint), seven are at further consideration stage (where we ask should we investigate the complaint) and ten are being investigated.
- Of the ten investigation cases, we have issued two provisional decisions; are drafting two; have received the relevant evidence in three cases and are awaiting evidence in five. We have accepted five cases for investigation since the start of April, the same as in the previous three months. We are modelling closely the conversion rate to investigation to ensure we have the appropriate resources in place.
- On the whole, our complaints management system is still working well and the early teething problems with firms accessing messages via the online portal have been resolved. We have one group of firms that we communicate with via email because it is not possible to set up the same contact for the Group of firms within the case management system. Tizo are working through providing a fix for this issue, but it is not straight forward.
Creditor engagement
- We are considering a wider plan of engagement with creditors, and a paper on our approach for 2025-26 will be presented at the July Board meeting, as discussed at the March Board meeting. In the meantime, creditor engagement continues – including a March meeting with an energy firm’s Vulnerability Team, at which we agreed to work together on what a “good creditor” approach might look like. We have also agreed to lead an ECB session on vulnerability and ability to pay at the June IRRV regional forums, which take place across the country and are a good way to reach a large number of creditors and enforcement firms.
- We are continuing to build awareness and engagement with the ECB amongst parking creditors and will be speaking at a number of British Parking Association events in the coming months, including Parkex in Coventry.
Communications and Engagement
- Throughout March and April, we have delivered our regular contributions to the trade press and continued to increase our social media presence with a steady flow of Linked In and X posts. This includes articles for the High Court Enforcement Officers Association and social media on our new Standards and our business plan.
- At the previous Board meeting we agreed to stop using X and to consider alternative platforms such as Bluesky. Having looked at Bluesky’s audiences and reach, we feel it would be useful to conduct a wider review of our approach to communications so that we can make the switch with the benefit of this. We intend to map our key audiences and the platforms they use, and develop a strategy that allows us to speak to different audiences in different ways, rather than the “one size fits all” approach we’ve tended to take.
- We have had meetings and attended events with a number of stakeholders since the last Board meeting.
These include:- Meeting Helen Undy, CEO of Money and Mental Health Policy Institute
- Meeting Steve Vaid, CEO of Money Advice Trust
- Attending the Treasury’s Debt Fairness Group
- Attending the launch of StepChange’s new five year strategy
- We have also engaged with the industry and continued our regular Ministry of Justice meetings.