Introduction
- Since the Board last met we passed the milestone of one full year since the Ministry of Justice announced their commitment to legislate to give the ECB statutory powers. We have done a lot of concentrated communications and public affairs activity to shine a light on this and increase the pressure on government to make concrete progress on delivering this commitment.
- With a new PM and cabinet on the horizon, we have come through this period with a larger group of committed and engaged MPs to help us to keep up the political pressure on the new team to deliver.
Financial management update
- The total expenditure at the two-month point in financial year i.e. to the end of May was £270,236 (April: £128,251) against the forecast budget of £289,855 (April: £140,405) giving an underspend against the reforecast budget of £19,619 (April: £12,154). The variances largely arise from phasing of certain budget lines and there are no material differences to draw to the Board’s attention at this point in the financial year.
- In terms of the balance sheet, the cash position as at the end of May was £210,194 (April: £283,367). Accounting for current liabilities, our net current asset position was £1,206k (April: £216,958).
- We issued levy invoices to the top eight firms in May, and also to Local Authorities in early June. We are currently showing a shortfall of £444,264 on budget owing having £463,883 left to invoice (with a small number of firms having requested quarterly payment plans).
Annual report and accounts
- The draft annual report and accounts 2025/26 is presented as a separate agenda item for the Board to sign off, ahead of filing with Companies House.
Staffing update
- The Head of Complaints will be leaving her role later in the summer, after two productive years in post. This will result in some changes within the team, the result of which means we are currently recruiting a Complaints Assessor to backfill the resource gap that will emerge. Further structure changes are being held off until after the outcome of the process and efficiency review have been reported, later this financial year.
- The Director of Government and Risk will also be leaving the ECB later this summer following an extended period of secondment from the Ministry of Justice. The Board will no doubt wish to extend its sincere thanks to both the Head of Complaints and the Director of Government and Risk for their significant contribution to the work of the ECB, particularly their work in the set up and operational phases of the organisation.
- We held a team day in London on 1 July where we had sessions on the vulnerability standards and discussed issues related to some live complaints. We also held leadership team days in London on 10 June and 8 July, where we considered the work plan and other live matters.
Data Protection and IT update
- Our Managed IT Services providers, Elysian, have now completed six months of support for the ECB, having started on 1 December 2025. The helpdesk service continues to perform very well.
Data protection update
- Following the discussion at Board last month, we have sought legal advice on our approach to handling an increasing number of Subject Access Requests (SARs) all of which arise from the complaints work. We will provide an oral update at the meeting.
Oversight and Thematic Review
- The Thematic Review on fee linking and charging was published on 4 June and has been generally well received. We shared a Press Release with trade press, posts on our Linked In page, and articles for CIVEA and the HCEOA.
- We have now started a series of workshops with the industry to start the process of developing new draft standards and guidance in this area. The sessions we have had so far have been constructive and helpful.
- The Board has a separate paper that sets out our plans for development of our wider risk and compliance function over the coming year.
Policy and standards
- We are in the process of drafting the guidance to accompany the vulnerability standards. This will take the form of guidance boxes weaved into the existing standards as well as some case study examples and relevant resources for firms.
- Our intention is to share the draft guidance with firms and debt advice stakeholders at the end of July, ahead of hosting three workshops in August, to which we have invited all the firms we oversee. The focus of the workshops will be on application of the guidance and standards to case study examples. In addition to this, we have also arranged to attend a meeting of the Taking Control Group to receive their feedback on the guidance. We then intend to publish the standards with incorporated guidance in September. As the guidance is expanding on the detail of agreed policy rather than introducing new concepts, we are not planning to share it with Board for approval. We will share the draft guidance with the Chair for comment, and will circulate to Board for information, ahead of sharing it with industry.
Complaints handling
- As of 1 July, we had 151 live cases. The cases are distributed as follows: 14 at Initial Consideration, 27 at Further Consideration and 110 at investigation stage.
- Of those at investigation, 7 are at draft decision stage, 17 are under investigation with the remainder (86) pooled for allocation.
- Incoming work has been distributed as follows: April 106, May 83 and June 94. And so, incoming numbers are consistent with our estimate of receiving 80 to 100 complaints per month.
- By 30 June we had received 279 complaints and closed 302. Those were closed as follows: 190 at Initial Consideration, 60 at Further Consideration and 52 at Investigation stage. Our performance against our KPIs is as follows:
| Complaint Stage | Target | Cases | Performance |
| Initial Consideration | Consider in 5 working days (from receipt) | 287 | 88% |
| Further Consideration | Consider in 15 working days (from receipt) | 121 | 22.5% |
| Investigation | Close in 90 calendar days (from Invest.) | 52 | 8% |
- In 69.5% of cases, we issued the decision whether to launch an investigation in 15 working days or less (this is a combination of initial and further consideration cases).
- There has been a reduction in our performance against our initial consideration KPI. We have explored the reasons for this, and they largely relate to delays in receiving information from accredited firms. We have identified the top three firms, which account for 57% of the missed targets. We are in the process of contacting them to test the reasons for this and to identify potential efficiencies.
- We are now moving to a point where all the cases awaiting further consideration and over 50% of the cases under further consideration are within the target of 15 working days. This is a much-improved position. However, due to imminent staff changes with the move of the Complaints Assessor to Investigator, the relevant recruitment to fill the role and working through the last of our older further consideration cases, it is likely this position will deteriorate slightly over the Summer.
- We continue to allocate investigations outside of the 90 day KPI. In my last update I reported that we are now allocating cases for investigation that are just under four months from the date of the launch of the investigation. However, as I indicated would be the case, there has been a slight deterioration of this position and are now allocating cases launched at the end of February. This is as a result of the increase in investigations launched as we have made headway into the queue of further consideration cases and changes in the Investigation Team.
- We have closed 52 investigations so far this business year. The investigation outcomes are set out in the table below.
| Investigation Outcome | Number |
| Not upheld | 32 |
| Partly upheld | 18 |
| Upheld | 2 |
- We have recommended a financial remedy in 13 cases totalling £1,575. Payments range from £50 to £300 and are awarded based on the impact of the issues identified on the individual.
- In addition, we have made 24 recommendations for reminders to be issued about the relevant Standards and / approach and have asked firms to change their procedures in a further three cases.
- Since my last report, we have received six decision review requests, closed four and have four in total that are under consideration. Of the four decision review requests completed we have not found a basis to change our decision, although further explanation was provided in one case.
- We have received two service complaints, one is awaiting consideration and in the other we apologised for a minor handling issue related to a decision review.
Political strategy and public affairs
- Work to secure statutory underpinning progressed during June.
- In early June, our focus was on identifying an MP willing to take forward the issue through a PMB. Discussions with Labour MP Jessica Toale were very positive: she was supportive of the policy objective and came close to submitting a Bill. However, the proposal did not succeed. Nevertheless, the engagement undertaken during this period has helped to maintain pressure on the Ministry of Justice to deliver statutory regulation in this parliamentary session.
- 9 June marked one year since the launch of the Government’s consultation. We used this milestone to issue a press release highlighting the lack of progress, which secured coverage in the Guardian and a small number of other publications. Martin Lewis raised the issue at Money and Mental Health’s 10-year anniversary event, and at the same event, Angela Rayner, former Secretary of State for MHCLG, referenced the need for statutory regulation. We will continue to maintain this relationship as part of our wider engagement strategy.
- I appeared on Good Morning Britain with Martin Lewis on 17 June to set out the case for statutory powers. Cabinet Minister Nick Thomas-Symonds responded on behalf of Government and acknowledged the need for progress in this session, as well as recognising the good work that the ECB has been doing. We have since followed up with his office.
- Red Rose continues to engage backbench MPs on our behalf. This has resulted in a number of Parliamentary Questions and has helped to identify further parliamentary allies. We are also working with Red Rose to develop a plan for September, when Parliament returns and when there may be changes to ministerial and adviser teams.
Communications and Engagement
- Members of the Executive spoke at a number of events during June. These included the LACEF conference, where the Director of Policy provided an update on our latest data; the HCEOA AGM, where the Heads of Complaints and Risk and Compliance Principal discussed emerging trends and the direction of future work; and two regional Money Advice Group meetings.
- Work has begun on an organisational communications plan. The aim is to ensure that we communicate more clearly about our impact during 2026/27 and that our communications activity is underpinned by a clear strategy. The first stage has been to review existing outputs and clarify their audience and purpose. The Director of External Affairs will present an organisational communications plan and strategy to the Board in September.
Quarterly work plan
- At Annex A, there is a quarterly work plan that sets out our planned activity in delivering the work from the 2026/27 business plan. This plan accounts for the staffing changes that will be occurring over the summer, as outlined above.
- In developing this plan across all areas of the business, now that we have a final business plan, we have a better sense of when we will be delivering the different strands of work. Most of the delivery plans are in line with previous material seen by the Board. I particularly draw Board’s attention to two key matters:
- We are planning to launch the public consultation on new fees standards and guidance by November 2026. As set out above, work is already underway to develop our proposals. We had previously discussed, tentatively, late September/early October to launch the consultation. For resourcing purposes and also to ensure that we manage requests from stakeholders efficiently alongside other projects (notably vulnerability where we are doing significant work over the summer and early autumn), we now believe that a November launch is required. We believe this will maintain momentum and also have the benefit of not overwhelming the industry alongside vulnerability implementation.
- In relation to the data returns, we are planning to develop an updated suite of metrics across early 2027, to come into effect for DR7 from July-December 2027. The primary changes will relate to data capture around the new vulnerability standards but we will also use this opportunity for a more general update, streamlining and consideration of other data points. The data return process is currently working well and we believe it is important to consolidate changes rather than introduce regular changes. It is not practical in resource terms to do the work required to introduce consolidated changes sooner than this, especially given the need for a smooth handover from the Director of Government and Risk of this workstream.
- The workplan is ambitious but, with the points noted above, we are confident of delivery with the resources we have available. The timing and extent of work required from any progress on statutory powers is the main unknown. We will monitor the workplan closely as a leadership team and inform Board of any changes that we think may be required as a result of significant external developments.