Chief Executive’s Report, June 2025

Introduction

1. This meeting comes hot on the heels of the last in-person one but even with only five weeks to report on, there is a lot to update on. As our operational functions really start to gather pace, the focus and feel of the organisation is evolving. It is really energising to see the processes and approaches that we have been building over the last two years being applied in practice, particularly to help members of the public with their complaints.
   
   
2. We have a considerable number of external engagements planned for June and so we are gearing up for this and are really looking forward to getting into some workshops and discussions on our plans on vulnerability and ability to pay. As we have always sought to emphasise, it is through this wide and open engagement, taking account of a wide range of viewpoints, that we will be able to ensure that we are best placed to achieve our mission.  

Financial management update
Levy

3. The new round of levy collection, starting with the largest firms and Local Authority in-house teams, began in early May and we expect to complete this first round by the end of June (subject to any agreed payment plans).
   

Year end 2024/25

4. The 2024/25 year-end expenditure position has barely moved since the figures provided to the April Board, with just a small number of accruals coming through, mainly in the form of expenses. Board members are reminded to submit any outstanding expenses claims for the period ending 31 March 2025.
   
   
5. As last year, we plan to submit our annual accounts to Companies House early, by the end of July. The final year end accounts alongside the Directors’ Report will be presented to the Board in July, for sign-off.
   

April management accounts – summary

6. Total expenditure for the month of April was £74,412 against a budget of £95,062, giving an underspend of £20,650. The underspend is largely a consequence of phasing and timing of expenditure, as well as some invoices being received later than expected.  
   
   
7. The cash position as at 30 April was approximately £459k (at this point last year, the figure was £348k). Accounting for current liabilities, our net current asset position is £338k (last month, £413k) and this figure is expected to increase next month as levy income is received. The larger-than-usual current liabilities are mainly the result of a large repayment to be made to an enforcement firm that overpaid their levy in 2024/25; this payment has now been made and will see our current liabilities returning to a more routine level next month.
   

Bank transfer

8. We are progressing the switch of banks, and hope to have the transfer completed within the next two weeks or so. The process has been more lengthy and administratively burdensome than we had hoped, but we look forward to account management via an app and multiple linked bank accounts which will allow us to set up a separate reserves account and expenses account with capped debit cards, as previously reported.  
   

Staffing update

9. Liz Thompson, previously Head of Compliance at the Lending Standards Board, joined on 1 May as Risk and Compliance Principal. Our Complaints Investigator will be leaving the team at the end of June to take up a role in Metrobank, and she will be succeeded on 10 July by a new Complaints Investigator, who joins us from the Financial Ombudsman Service.
   
   
10. We have also appointed a new Complaints Manager, who will be joining us on 30 June – this will provide some needed resilience and additional resource to the complaints team, as discussed at the Board meeting in April. With the addition of this new manager role, this will conclude our planned recruitment for 2025/26.
    
    
11. We held a successful team day in central London on 21 May, where the focus of discussions was on our achievements over the last two months, as well as looking ahead to the very busy work programme over the next three months. We will be holding our next team development day in Manchester on 2 July.

Data Protection and IT update

12. We continue to make good progress against the Data Protection Implementation Plan presented to the Board in January. Recently completed tasks on the implementation plan include:
    
    • Updates to the privacy notice on our website.
    • Registration of the new Director of Corporate Services as the ECB’s new Data Protection Officer.
    • Introduction of two-factor authentication for all staff, with the plan to roll this out to Board members in due course.
    • Completion of an IT contract invitation to tender, where we will be specifically looking for service provision to include data protection and security. We will be asking providers to include data resilience, business continuity, and security audits. The invitation to tender will likely launch in June.
    
    
13. There have been no significant data incidents since the last Board meeting.
    
    
14. Our outsourced IT team have set up 365 Backup, which backs up 365 emails, OneDrive, SharePoint and Teams data three times a day (subject, over time, to a retention schedule).

Accreditation

15. At the end of May we confirmed the accreditation of OneSource, an in-house team providing enforcement services for Havering, Newham and Bexley councils.  We now have the prospect of increasing the number of accredited internal teams to 11 with another Welsh in house team, which has recently sought further details on accreditation. The Director of Policy & Oversight will be following this up and plans to visit this team around the July Board meeting in Abergavenny.

ECB Standards Development

16. The Board has a draft discussion paper on vulnerability and ability to pay on the agenda for this meeting.
    
    
17. The majority of Self-Assessment returns were received by the 30 April deadline. At the time of writing there are just four returns outstanding which have now been chased at least twice. The Director of Policy & Oversight will be determining next steps to obtain the outstanding returns. All returns are due to be reviewed and the content will be used to help populate the new risk assessment framework.

Complaints handling

18. Our complaints casework is growing.  As of 23 May, we have 34 live cases.  They are distributed as follows: 7 at Initial Consideration, 1 awaiting Further Consideration, 6 at Further Consideration and 20 at Investigation. 
    
    
19. With the departure of the Complaints Investigator on 27 June, we have put in place a plan to manage incoming work until her replacement starts on 10 July and the Complaints Manager joins us on 30 June. The focus is on ensuring investigation cases are progressed, while at the same time redistributing the Further Consideration decisions, where that is possible. This presents a significant challenge in terms of meeting the 15 working day target for Further Consideration. We have a communication plan in place to manage the expectations of the parties at the time complaints pass to Further Consideration and to keep them updated.
    
    
20. We have closed 125 cases. 112 at Initial Consideration, 9 at Further Consideration and 4 at Investigation stage. We are performing well in terms of our KPIs as follows:
    

Complain Stage	Target	Cases	Performance
Initial Consideration	Consider in 5 working days (from receipt)	152	97%
Further Consideration	Consider in 15 working days (from receipt)	34	97%
Investigation	Close in 90 calendar days (from Invest.)	4*	100%

*^{One closed on basis complainant raising further linked issues with enforcement firm, which should be completed.}

21. We accepted 9 cases for investigation in April and 9 so far in May. We have resolved 3 cases prior to investigation stage.  In those cases, we have either provided an explanation for the process that has been followed or the resolution offered, and they have been accepted.  We believe that providing that explanation is a proportionate way to resolve complaints without the need for a full investigation.
    
     
22. We have considered one service complaint, and one decision review request related to the same case.  We have amended our process for issuing initial consideration decisions in the light of the service complaint, but were satisfied our decision was appropriate.
    
    
23. Overall, our complaints management system is still working well. We are working with our provider on changes to the dashboards that will help us to better monitor and manage the workload. 
    
    
24. In terms of requesting and storing demographic information within the Tizo system, Tizo are currently exploring the possibility of using another application to request and store the demographic questionnaire with a workflow created from. The information will then be stored securely and separately from the case handlers in the system.  This is in the early stages of consideration, and we are working with them closely on this.
    
    
25. Following from last Board meeting, we have discussed the use of AI informally with an Ombudsman colleague and with Tizo. The key is to use AI in a way that is secure and supported through our case management system. AI is not currently part of the functionality offered by Tizo. However, this is an area of development for Tizo, and they have collaborated with a market research company on this and spoken with a relevant Ombudsman scheme. They have provided a report looking at where AI might be feasible and potential areas identified for development are:
    
    A) A vulnerability scanner that scans to look for key words that flag a potential vulnerability (this is currently being beta tested)
    
    B) Categorisation of data
    
    C) Allocation of casework
    
    
26. Tizo are looking at options for taking this forward and we will be able to use that when it is in place. 
    
    
27. The Memorandum of Understanding (MoU) with the Local Government and Social Care Ombudsman (LGSCO) is due to be published on 28 May and we have received a draft MoU from the Public Services Ombudsman Wales (PSOW), which we will review.

Creditor engagement

28. We are considering a wider plan of engagement with creditors, and a paper on our approach for 2025/26 will be presented later in the year. In the meantime, creditor engagement continues – including a May meeting with Eon Next’s Vulnerability Team, at which we will discuss what a “good creditor” approach might look like. We will also lead an ECB session on vulnerability and ability to pay at the June IRRV regional forums, as set out in below.
    
    
29. We are continuing to build awareness and engagement with the ECB amongst parking creditors with the CEO speaking at the British Parking Association ‘Parkex’ on 22 May, and the Director of Policy & Oversight speaking at the British Parking Association Live conference in Peterborough in June.
    

Communications and Engagement

30. Our stakeholder engagement has stepped up in recent months, with the extra capacity that the Director of External Affairs brings. Our focus has included building or re-establishing relationships with debt advice organisations, with the purpose of setting out our vision for statutory powers and understanding how they might respond to the consultation when it comes. To this end we:

• attended the Money and Mental Health Policy Institute strategy launch
• met with the Director of External Affairs at Citizens Advice
• met the Head of Policy at Christians Against Poverty
• met the Head of Policy at StepChange

31. The Director of External Affairs and the Director of Policy and Oversight held meetings with the Welsh Local Government Association to provide an update on the ECB’s work and better understand how enforcement policy and practice has changed in Wales. Both parties agreed that there is scope to work together and drive further improvements in Wales and to that end the ECB will now seek a meeting with Minister Hutt.
    
    
32. The CEO, Director of External Affairs and Director of Policy and Oversight will present at ten IRRV Forum events across England and Wales in June. This will be a chance to provide a Local Authority (and Enforcement industry) audience with an update on our work and hold a discussion on our upcoming vulnerability and ability to pay standards. We will also publish an article in the IRRV magazine, “Insights”.
    
    
33. The Director of Policy & Oversight will also be taking part in a live Podcast at the Institute of Money Advisers conference in Birmingham on 12 June, speaking about the achievements of and prospects for the ECB on a panel chaired by the ex-MP Yvonne Fovargue, a long-term supporter of statutory powers for the ECB.
    
    
34. The Memorandum of Understanding with the Local Government Ombudsman is due to be published on 28 May and will be hosted on both parties’ websites. In addition, we will issue a joint press release and share the news via our stakeholder newsletter.

Political strategy and public affairs

35. We are still awaiting news of the consultation on statutory powers but remain hopeful that it will be published before Parliament breaks up for the summer.  The Director of Policy & Oversight will provide an oral update for the Board at the June meeting and in the meantime we are preparing our Communications plan and assets and beginning work on the Blueprint.
    
    
36. Following the conversation with Board on 30 April, we met the Small Business Commissioner to test our arguments on growth and small business.
    
    
37. Enforcement regulation continues to gain traction in Parliament. On 13 May StepChange ran a ‘drop in’ event for MPs to find out more about their campaign for regulation. The Director of External Affairs was invited to speak to MPs about the work of the ECB and why we need statutory powers. Approx 15 MPs and Peers came to the event and we have provided them with a written briefing.
    
    
38. On 21 May Luke Charters MP presented the “Bailiff Regulation (Assessment and Report) Bill to Parliament. It proposes that Government “publish an assessment of the effectiveness of current regulation of the debt collection and civil enforcement sectors and to report to Parliament on the potential merits of statutory regulation of those sectors”.
    
    
39. Finally, HM Treasury has recently invited the ECB to become permanent members of the Government Debt Management Fairness Group, which places the ECB closer to policy-making on Government debt enforcement policy (while retaining our independence) and provides us with another forum for advocating ECB statutory powers.