Chief Executive’s Report, November 2025

Introduction

1. This month has seen our operational oversight really starting to bite, as the oversight team has visited five firms as part of the thematic review on overcharging. At the same time, the Complaints Team continues to investigate a growing number of complaints. This is inevitably leading to an evolution of our relationship with accredited firms, as we start to delve in to how they are operating and identify areas where changes or improvements are required. Overall, the early signs in relation to this shift have been encouraging.
   
   
2. At the same time, we continue to progress some key policy work around the Vulnerability and Ability to Pay standards, which generated significant feedback and responses to our consultation.
   
   

Board Matters

3. The Board is invited to agree the resolution attached at Annex A, to effect an update to Companies House that Delory Corinaldi will be appointed to the Board from 1 January 2026.
   
   
   

Financial management update

October management accounts – summary

4. Total expenditure for the first seven months of the financial year i.e. to the end of October was £810,168 against the reforecast budget of £825,861, giving a small underspend of £15,693. The underspend resulted largely from a slight underspend on salaries and otherwise related to phasing and timing of expenditure.
   
   

5. In terms of the balance sheet, the cash position as at the end of October was £859,760. Accounting for current liabilities, our net current asset position is £1,038,367.
   
   

6. The scoping paper for the business plan and budget 2026/27 is presented as a separate item on the agenda.

Staffing update

7. We held a successful leadership team day in Leeds on 12 November where the focus of the discussion was on scoping the business plan and budget 2026/27. We also reviewed the current workplan and discussed contingency plans for managing the ongoing pressures in the complaints team.
   
   

8. We held a team day in London on 22 October which comprised a morning session with our new provider Sherry Design, where we had the opportunity to discuss with them matters such as our branding, social media presence and website, and we also had an interesting session on the data returns report, as presented to the Board’s October meeting.
   
   

9. A new team member will be joining us on 15 December to take up the post of Complaints Investigator. This candidate is joining from an accredited enforcement firm and as such, will bring existing industry knowledge. We are also in the process of recruiting a Complaints Assessor to the team. This will be followed by a further external recruitment to appoint another Complaints Investigator. 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.

Data Protection and IT update

10. Our new Managed IT Services provider will be taking over support for the ECB on 1 December 2025. They are currently in the process of undertaking an audit of the current arrangements, and are holding sessions with the outgoing provider, and with key ECB team members. The Director of Corporate Services will keep in touch with Board members on the logistics of the transfer to the new provider, should there be anything specific we need Board members to do.
    
    

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

Accreditation

12. We have now concluded 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 also involved collection of the levy from all firms that have not yet paid the levy for this year.
    
    

13. This process ran smoothly this year and we now have 42 accredited firms and two accredited in-house teams at Local Authorities (LAs have until the end of November to send in their applications). We had two small firms withdraw from accreditation this year – one because they are no longer doing any TCOG work and one that has made an active decision to carry on doing a small amount of TCOG work without being accredited. We are seeking to address this with the firm to bring them back in. 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

14. The Oversight Team provide an update on the Thematic Review on fee charging in a separate paper for this Board meeting.

ECB Standards Development

15. The public consultation on the new Vulnerability and Ability to Pay Standards closed on 31 October 2025. During the six-week consultation period we undertook engagement activity including a meeting with the Taking Control Coalition, a structured in-person industry workshop and two industry ‘drop-in’ sessions. The industry sessions were well attended with participants providing robust and wide-ranging feedback on the Standards.
    
    

16. In total we have received 30 consultation responses, ranging from a few key points to comprehensive responses to each of the consultation questions and analysis of the new Standards. Industry respondents include CIVEA, the High Court Enforcement Officers Association and a range of the larger firms as well as some accredited local authority in-house teams. The debt advice and third sector were represented by the Taking Control coalition, some individual charities and debt advice providers, and the Money and Pensions Service. The IRRV and two utilities creditors also responded.
    
    

17. We are currently reviewing the consultation responses and considering any changes to the Standards that might be needed as well as drafting a report highlighting key themes and our response to the feedback received. As might be expected, there is a divergence of views in a number of areas and some concerns about the detail of how the Standards will work in practice. Equally, there is an encouraging sense that overall, the new approach to VA2P and the Standards are reasonable, build on existing good practice in many areas and should achieve the desired cultural shift in the industry and improved outcomes for people experiencing enforcement.
    
    

18. Findings from the research with people with lived experience of enforcement and Enforcement Agents will also be fed in to the response and any further development of the Standards. The research company is currently drafting reports on each with a view to us publishing all or part of these when we launch the final Standards.

Complaints handling

19. Our complaints casework continues to grow but at a much slower rate than previously. As of 16 November, we had 114 live cases. They were distributed as follows: 9 at Initial Consideration, 29 at Further Consideration and 76 were at investigation stage.
    
    

20. Of those at investigation, 11 are at draft decision stage, 13 are under investigation with the remainder pooled for allocation.
    
    

21. Incoming cases to the ECB had remained consistent between June and September, with between 80 to 100 cases being received per month. That dropped slightly in October to 78 and we have had a slow start to November, with only 23 cases received so far.
    
    

22. The reasons for this are not clear and complaints often come in waves and so it seems more likely than not, given what we know about complaints, that numbers will increase again. However, given the sudden departure of the Enquiries Officer (who was working for us as a contractor on a fixed term basis), coupled with holiday and the leave of another team member, the short reprieve in incoming work has been helpful. Despite that, we accepted 14 complaints for investigation in October and have accepted three so far in November. Plans for managing incoming work to complaints while we are recruiting are set out in the Complaints paper.
    
    

23. However, with the departure of the Enquiries Officer cases are taking longer to progress through further consideration than had otherwise been the case. We currently have 29 cases awaiting further consideration (10 of which are being actively worked on) and so it is likely that will generate another 20 investigations. Plans for managing that work are set out in the Complaints paper.
    
    

24. To date we have closed 504 cases, 402 at Initial Consideration, 48 at Further Consideration and 54 at Investigation stage. Given the higher than anticipated demand and resourcing challenges, our performance against our KPIs is not where we would want it to be. 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.
    
    

25. 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.
    
    

26. 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 6 cases.
    
    

27. Since my last report, we have completed the two outstanding decision review requests.  We supported the ECB’s original decision in one but decided to re-open another decision to undertake the initial consideration again.  That case has been appropriately prioritised.
    
    

28. We have also received one service complaint and a Judicial Review claim form, which are being processed. 
    
    

29. Our work to improve our case management system continues.  We are not yet satisfied with our first suite of reports and are liaising with our case management provider to improve matters.  This has been the focus of our liaison over the last 6 weeks. 
    
    

30. The demographic questionnaire went live on 1 November 2025 and for the first time we can collect and report on the demographics of our complainants.
    
    

31. Since my last report, Board agreed the MoU with the High Court Enforcement Officers Association and the MoU with the Public Services Ombudsman for Wales has been agreed with PSOW and is in the process of being finalised to circulate to the Chair to approve out of Board (in line with the agreement at April Board).

Political strategy and public affairs

32. The Director of External Affairs and Director of Policy and Oversight will attend a Taking Control Coalition meeting on 20 November to discuss further opportunities for keeping up the momentum on Statutory powers. We will be writing to the Secretary of State for Housing, Communities and Local Government to ask him to support speedy legislation. Given the interest in Council Tax enforcement at the moment, statutory regulation would be beneficial to his department.
    
    

33. We were due to meet Minister Sackman in November for further discussions on the Statutory Regulation consultation, but the meeting has been postponed until January. In the interim, we will write to the Minister with examples from our oversight and complaints work, to help her make the case for legislation in this Parliamentary session.  The CEO and Director of External Affairs also met the Deputy Director of Civil Justice Law Policy and MoJ on 17 November.

Creditor engagement

34. We have continued to engage with firms and agents to build our knowledge and understanding of the realities of working in the industry. I spent a day at an Essex-based firm’s head office in November, reviewing body warn video footage and listening in on calls, and the Director of External Affairs shadowed a High Court agent in London. We also ran a number of workshops for firms on the draft Standards, as set out above.
    
    

35. I spoke at the British Parking Association Enforcement Forum in October and we intend to build our relationship with that group further next year. The Director of External Affairs and I also attended the annual MALG conference in Leeds for discussions on debt policy. I took part in a panel discussion on public sector debt collection, in which I set out our vision for better assessment of ability to pay and vulnerability. In October we took the decision to join MALG, which means we now have access to their regular forums and meetings, which will prove helpful as we build our understanding of creditors and broader approaches to debt collection.
    
    

36. The October Stakeholder Engagement Forum was well attended. As well as providing updates on ECB business, we ran a workshop on how we might measure the impact of our Standards. Attendees made a number of useful suggestions which we will follow up on in due course.
    
    

37. Engagement with our LinkedIn page is stable. We gained 32 new followers in October but engagement with our posts was significantly higher than it was in September, likely because we have begun to use more photos and introduce more variety.