It was an online Board meeting in November and it was excellent to have our second new Board member, Delroy Corinaldi, observing the meeting in preparation for starting on the Board formally from January.
The meeting started with an update from the team on the Thematic Review on overcharging of enforcement fees. It was positive to hear of the progress that the team has made so far, with five visits to firms already completed. Equally, it was encouraging to hear that every firm that has been selected so far appears to have engaged positively and openly with the process, helping the review to run smoothly. One of the areas we discussed was wider learning opportunities from this review into the culture and monitoring systems at firms and how this can be applied in the future as we develop our wider programme of oversight visits to firms. We are looking forward to future updates as the review progresses.
We moved on to an item on complaints. The Board has discussed emerging numbers and trends in complaints regularly this year, based on the updates provided in the CEO’s Report. This was the first time that we were able to scrutinise a full consolidated report – which looked at the first nine months of data.
We discussed the fact that complaints to the ECB are higher than we had anticipated when we did our resource modelling last year. We are receiving upwards of 100 complaints a month and around 20% of these are currently leading to an investigation, which is generating a significant volume of work. We have been upholding more than half of the complaints that have reached a decision after investigation. This relatively high uphold rate suggests that we are targeting our investigation resource well. The Board discussed the issues that we have found in upheld complaints, which cover a wide range of areas and have uncovered some concerning behaviour. We also noted that in some of these concerning cases, the first-tier complaints handling had not found any issues.
The team reported that accredited firms have been engaging positively with this process, accepting our findings and committing to implement improvements beyond the specific cases in hand where necessary. We talked about the importance of increasing our oversight follow-up in these cases, to ensure that wider improvements are being delivered well. This interplay between complaints and oversight is where the ECB can really drive up standards. This is one of the reasons that in 2026/27 we want to bring in another person to the oversight team to support our Risk and Compliance Principal.
The high demand for complaints means that we are not consistently meeting our ambitious KPIs for timeliness and the Board discussed this issue and what to do. The complaints team is already set to receive three new members over the coming months and this will make a big difference to capacity. We also stressed the importance of conducting a process and efficiency review of our complaints process next year, which should also include a review of our KPIs. The team presented some analysis which showed that our existing KPIs are much shorter than comparable bodies. We are committed to delivering a swift and proportionate service but within this there may be scope to slightly increase some of the timeframes in our KPIs in the future, to provide a bit more headroom.
Having considered the evidence from complaints, we then had an update on plans for publication and launch of the ECB’s first Insights Report in January 2026. This will bring together the evidence we have gathered so far from complaints, data returns and oversight activity in one place. We intend for this report to contribute to increased overall understanding across the market on how the industry operates and where the risks lie.
And lastly, we came to an early scoping paper on business plan and budget. As in previous years, we will consider a draft business plan and budget at the January Board meeting and will consult after that, before agreeing a final plan and budget in March. So, this was an opportunity for an early discussion about what we want to see in the next business plan.
Our focus for 2026/27 will remain on the five priority areas outlined in our existing Business Plan. And much of our activity for next year will be continuation and development of work that we have already started or committed to. A key focus will be further developing and embedding our core oversight framework. There will also be significant activity in relation to our complaints process. This will include increasing our capacity but also, as already noted, undertaking a full process and efficiency review to identify opportunities to maximise efficiency and ensure we are applying resources smartly and are well placed to meet future increases in demand. We also want to make sure we are able to devote more time to feeding back to industry on the issues and learning opportunities that we are identifying.
Beyond our core operations, we expect there to be work flowing from the Ministry of Justice advancing legislation to the put the ECB on a statutory footing. And the Board also reiterated its desire to increase our focus on influencing positive creditor behaviours, to ensure upstream behaviours that can support or hamper fair enforcement are better understood and acted on. Linked to this, the Board asked the team to work up proposals for research looking at the demographics of people experiencing enforcement action – to advance overall understanding of who is experiencing enforcement action and how this might inform efforts to ensure fair enforcement.
In terms of the draft budget, the Board discussed that the coming year will require a re-basing of expectations around our budget and levy. This is the first year that we will be able to set the budget based on actual experience of operating our core complaints and oversight functions. And based on the emerging evidence in terms of numbers of complaints, as well as the issues we are starting to uncover from complaints and oversight work, it is clear that we will need to grow the team in these areas.
At the same time, the Board remains committed to ensuring that we are a compact, remote and smart oversight body that delivers its impact through targeted and proportionate action rather than seeking to have ‘boots on the ground’ across England and Wales. We remain mindful of the economic climate and the impact on the industry, as well as the fact that the fee rise that the MoJ has committed to deliver has not yet materialised (although we expect that to be addressed soon).
When we consult on the draft Business Plan and budget in early February, we will set out more detail on the workplan, budget and staff team and welcome feedback on this.
As this is my last blog of 2025, I wanted to note my ongoing gratitude to all of our stakeholders who have contributed to an impactful year in advancing the mission of ensuring that everyone who experiences enforcement action is treated fairly. We are very grateful to the contributions of views and evidence through our workshops and consultations, as well as to the early signs about how industry is reacting to and engaging with operational oversight. This all leaves us well placed for what looks like an important and busy year ahead.
Catherine Brown
Chair, Enforcement Conduct Board