Chief Executive’s Report - October 2026

Introduction

This Board meeting comes relatively soon after the September one and, as the Board pack shows, we have been working on a number of significant matters in preparation for the October Board.

One area that is particularly pleasing is that we have started the pilot visit programme, with visits now in the diary for the first three enforcement firms. This will become a core aspect of our ongoing compliance monitoring so it is good to be in the field, starting to proactively assess firms’ compliance with our standards.

Board matters

The Board completed its annual evaluation exercise this month, and the results will be discussed in the private session.

Financial management update

The total expenditure at the five-month point in financial year i.e. to the end of August was £712,265 (July: £556,178) against the forecast budget of £743,988 (July: £586,517) giving an underspend against the forecast budget of £31,723 (July: £30,339). 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, beyond an overspend in staff travel and subsistence – which is dealt with in more detail as part of the budget reforecast paper which is elsewhere on today’s agenda.

In terms of the balance sheet, the cash position as at the end of August was £771,080 (July: £796,199). Accounting for current liabilities, our net current asset position was £798,113 (July: £766,869).

We are currently showing income of £1,165,169 which represents a shortfall of £465,338 given four firms requested quarterly payment plans. The most recent quarterly instalment invoices have all now been paid (as at 21 September). We will be sending invoices to the remaining firms and LAs at the end of September / early October.

Our reserves are currently £798,113, and we are on track to end the year with reserves of £457,478 representing 3.1 months of operating budget.

The budget reforecast for 2026/27 is a separate item on the agenda.

Staffing update

We held a team day in London on 23 September where we were joined by our external HR adviser who led a morning session on how to get the best out of the team in a remote working environment. We also had updates from the complaints team on some live cases, and a session on future changes to our website. The leadership team met on 9 September, where the focus was on the workplan, and we also held a meeting with the team at MoJ to discuss statutory powers.

Data Protection and IT update

We held two online training events for colleagues in September on using Copilot Enterprise following the deployment of the full Copilot licenses across the organisation. In early October, a sub group of staff will be trained on developing agents within Copilot.

There are no data protection matters to draw to Board’s attention at this time.

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. Changes since the plan was presented Board in July are shown in tracked changes.

I particularly draw Board’s attention to two key matters:

(i) Statutory powers and impact on workplan – there are some new areas of work introduced to Q3 and Q4 in line with the paper on this subject in the Board pack.

(ii) We are proposing to push back launch of the public consultation on new fee guidance and standards. This is covered in the statutory powers paper in the Board pack. It is to ensure that this work lands at a sensible time in relation to statutory powers and also that we have capacity to prioritise the work required to be ready for implementation of statutory powers.

The workplan continues to be ambitious but, with the points noted above, we are confident of delivery with the resources we have available. The timing of the introduction of statutory powers is the main unknown. We continue to monitor the workplan quarterly as a leadership team and will inform Board of any changes that we think may be required as a result of significant external developments.

Oversight

The Risk and Compliance team have now conducted initial meetings with all the firms who will be participating in the Body Worn Video element of the pilot visits programme in advance of sending out the formal requests for evidence ahead of our visits.

There are three firms in total we will be visiting over the coming months to test our processes and to look at their adherence to our standards on Body Worn Video.

In addition to the in-person review visits we will also be conducting a desk-based communications review with a different group of firms later in the year.

Policy and standards

We have successfully completed the engagement on the vulnerability guidance, which have been shared with the Board for information alongside the papers for this meeting, and are preparing to publish the guidance in October.

We carried out a workshop with debt advice sector colleagues and a final workshop with firms which did not require any significant changes to the guidance. Alongside publishing the standards, we also intend to share our case study scenarios with firms directly to inform their preparation for the standards implementation in January.

Alongside the guidance we will also be making a technical change to the Agent’s Standards. The change relates to standard AS1.23 on third party payments. Currently the standard reads:
- ‘AS1.23 only seek payment from the person subject to enforcement, and only accept a payment from another person where:
  - AS1.23.1 this has been agreed between the person subject to enforcement and the other person without the enforcement agent influencing the other person; or
  - AS1.23.2 the person subject to enforcement has expressly consented to the enforcement agent discussing the debt with the other person, and the enforcement agent has not placed any pressure on that person to pay the debt.’

This standard sets out important protections for third parties and makes clear agents must not pressure third parties into paying debts on behalf of someone else. Another facet of the intent behind this standard was to prevent situations where a third party unconnected to the debtor (e.g. a new homeowner) might choose to pay a debt which is not theirs to avoid an EA visiting again even though the debt is not theirs to pay.

In the last year we have had a couple of complaints come to us where we have upheld a debtor complaint that a family member whom they live with has paid their debt on their behalf when they were not at home without their consent and they feel this caused them embarrassment.

This scenario wasn’t raised with us when we were drafting the standards. But it has exposed a gap in our standards where an agent can legitimately attend the debtors address when they aren’t at home and, if they are let in by a third party, proceed to take control of goods while the debtor isn’t present with the third party unable to make payment on the debtor’s behalf. This was not the intention of the standard so we are proposing amending the standard to add a new clause which reads:

‘AS1.23.3 the other person makes the offer to pay voluntarily without the enforcement agent influencing them, is known or related to the person subject to enforcement and resides, or is present at the address where the enforcement agent has reasonable belief that the person subject to enforcement lives or carries on a trade or business.’

As this doesn’t materially impact the intent behind the standards we are not asking for Board’s approval but sharing this change for information ahead of the publication of the standards and guidance in October.

Complaints handling

As of 22 September, we had 171 live cases. The cases are distributed as follows: 15 at Initial Consideration, 62 at Further Consideration and 94 at investigation stage.

Of the 94 cases at investigation stage, 20 have reached draft decision, 16 are under active investigation and 58 are pooled for allocation.

Monthly incoming complaints were: 106 in April, 83 in May, 94 in June, 98 in July and 109 in August, with a further 66 received by 22 September. August was the highest monthly volume recorded by the ECB since we launched our service in January 2025. We will continue to monitor incoming volumes to establish whether this was an isolated peak or evidence of a sustained upward trend.

Between 1 April and 22 September, we received 556 complaints and closed 554, meaning that overall closures broadly matched incoming demand during the period. Of the complaints closed, 349 were concluded at Initial Consideration, 97 at Further Consideration and 108 at Investigation. Performance against our stage-specific KPIs is shown below.

Complaint Stage	Target	Cases	Performance
Initial Consideration	Consider in 5 working days (from receipt)	557	88%
Further Consideration	Consider in 15 working days (from receipt)	199	20%
Investigation	Close in 90 calendar days (from Invest.)	108	6%

Performance against the Further Consideration KPI remains at 20%, with cases required to be actioned within 15 working days. The principal pressures have been the high level of new complaints received in August, and the time required to train the Complaints Assessor who joined on 17 August 2026. Improving timeliness at this stage remains a key operational priority as the new Assessor completes their training.

Although performance against the separate Further Consideration KPI remains low, 81% of all decisions on whether to launch an investigation were made within 15 working days when Initial Consideration and Further Consideration cases are combined. This has improved from 70% at the time of my last report and provides a broader indication of the timeliness of the assessment process overall.

Since last month’s report, the team has closed a further 28 investigations. This brings the total closed during the current business year to 108, already exceeding the total number closed in the full year ending 31 March 2026.

Two investigations were closed without an investigation outcome being issued, due to the complaint being discontinued or withdrawn before a decision was reached. The outcome of the remaining 106 decisions are set out in the table below.

Investigation Outcome	Number
Not upheld	60
Partly upheld	39
Upheld on all grounds	6
Resolved (resolution negotiated by the ECB)	1

Of the 105 investigations that resulted in an upheld, partly upheld or not upheld outcome, 45 were upheld either fully or in part. This represents 43% of those cases. One additional case was resolved through a resolution negotiated by the ECB.
The outcomes have resulted in a range of remedies and improvements. We recommended a financial remedy in 27 cases, requested an apology to the complainant in 42 cases, made 35 recommendations that firms issue reminders about the relevant Standards, and required procedural changes in four cases.
The investigation caseload has reduced to 94 cases, the lowest level reported this business year. Within that total, 58 cases are pooled and awaiting allocation, also the lowest level this year, while 20 cases have reached draft decision stage, the highest number reported this year. Together, these measures indicate improved movement through the investigation pipeline.
The improvement reflects the team’s growing experience, refocused internal performance targets designed to increase investigation output, and the transfer of the new Investigator from the Complaints Assessor role. We will seek to sustain this higher level of output and build on it through the changes arising from the process and efficiency review, which is covered in a separate paper to the Board.
Since my last report, we have received eight decision review requests and closed four. Five requests are currently under consideration. Of the four completed reviews, we changed the original decision in one case and found no basis to change it in the remaining three.
We received two service complaints during the period. Both identified minor service shortfalls, for which we apologised and took learning for the team.

Political strategy and public affairs

Following the Government’s August announcement on stronger regulation of the industry, the Leadership team met with the with MOJ Officials to confirm timings and the practical work that needs to be undertaken before the measure is implemented. A paper is included in the Board pack providing more detail, but key areas for development include a Memorandum of Understanding between the ECB and the Government, and changes to our existing Standards to ensure that they apply to ‘sole traders’ – Agents who work directly for creditors.
Our public affairs activity is currently focused on ensuring the Statutory Instrument is laid early in 2027 and is effective.

Communications and Engagement

We continue to engage with a range of stakeholders across the enforcement industry, debt advice and the wider creditor, debt collection and judiciary world. The Directors of External Affairs and of Policy presented at the latest Taking Control Coalition meeting, sharing our views on the Government’s announcement and seeking views on the vulnerability guidance, and separately I met with the CEO of Money and Mental Health to discuss their ongoing support. The Director of External Affairs took part in a vulnerability panel at the UK Credit and Collections Conference, and I provided an overview of the ECB’s latest work at the Civil Court Users Association conference. We are looking forward to attending MALG’s annual conference and the HCEOA luncheon next month.

Creditor Influencing

We have now confirmed the membership of our creditor working group. A kick-off meeting is planned for the end of October at which we will agree the terms of reference and workplan for the year, with the group then meeting bi-monthly to develop good practice principles. We’re also planning to spend some time on-site individually with each of these bodies over the coming months, to better understand what they do and where there is scope for improvement.
I met with Director of Operational Excellence at British Gas who are also keen to share more about their work to support fair collections.
We continue to engage with HM Treasury as the department responsible for ensuring Government embeds fairness into debt collection. This includes early conversations regarding a piece of work to be led by the Government Debt Fairness Group, codifying the steps that Government departments and public sector bodies must take immediately prior to enforcing debt recovery.