We were back in London for the October Board and it was fantastic to welcome our newest Board member, Caroline Wells, for her first meeting. Caroline has plenty of prior experience of the enforcement industry and was able to bring this to bear in the meeting. We’re looking forward to our other new Board member, Delroy Corinaldi, joining the Board in January.
We started the meeting with an excellent stakeholder session with Chief Executives and Executive Directors of StepChange, Money Advice Trust, Citizens Advice and Money and Mental Health Policy Institute.
It has been a little while since the Board had a session with colleagues in the debt advice and debt policy area, so this was a timely opportunity to catch up on progress, get feedback on the ECB’s work so far and talk about the opportunities for future collaboration.
We covered a lot of ground, including the need to continue making the case for statutory powers, to ensure a Bill to achieve this is laid in 2026. We also discussed the emerging evidence from our complaints service and ECB plans for making more evidence publicly available on the state of play in the market, through our forthcoming Insight Report (which we plan to publish in January).
We heard ongoing concerns about the practices of some Local Authority creditors in particular and hopes for reform in the area of council tax following the recent Government consultation. We also discussed the ECB’s current consultation on Vulnerability and Ability to Pay and the potential for these to drive positive change across the market.
After this session, the main Board meeting started with a paper on the initial analysis of evidence from the data returns for January to June 2025. This is the first full data return process, where all accredited firms provide data to the ECB across a wide range of data points. The data return analysis will be one of the main contributions to the Insight Report.
Board members interrogated the data and discussed areas where further analysis would be beneficial in advance of the Insight Report, as well as areas that suggest the need for further follow up through our oversight. We touched on areas including:
- The overall value of debt collected
- Increases in the recording of vulnerabilities
- Overall complaints numbers and the very low proportion of overall cases that result in a complaint
- Data on missing body worn video footage
- The prevalence of assaults against Enforcement Agents
- The relatively wide differences in results when comparing firms who do similar work.
It is clear that the data return process is going to be extremely helpful in advancing understanding of modern enforcement in practice and the Board is looking forward to further iterations of this analysis. We also noted that in November the Board will be considering analysis of the first 6 months of operation of our complaints process, which will be another key contribution to the Insight Report.
We moved on to consider the half year budget reforecast, which included a proposal to increase the ECB’s operational resilience for the remainder of the year, to address high volumes of complaints and the requirements to resource our thematic review on overcharging alongside wider oversight work. The Board scrutinised the proposals and agreed with the need to bring in some additional resource before the end of the financial year. We also discussed the importance of prioritising a process and efficiency review of our complaints service next financial year, once we have been operational for an adequate period of time and have a better sense of the emerging picture on complaints volumes. We expect complaints numbers to continue to grow and so it is vitally important that we optimise all opportunities to deliver an efficient and effective service.
The Board agreed the budget reforecast and proposal to forecast a small deficit this year, to be funded from the ECB’s reserves. We remain committed to building a prudent financial reserve for the ECB to safeguard our operation and mission, and this, along with investing further in our complaints and oversight work, will need to be reflected in the budget for 2026/7.
The last substantive item on the agenda was a discussion on longer range strategic opportunities for the ECB. By the end of this financial year, the ECB will be fully operational and delivering benefits across all of the key areas from the Taking Control for Good Coalition’s blueprint. Alongside this, we wanted to consider what other opportunities there might be for the ECB to contribute to ensuring that everyone experiencing enforcement action is fairly treated. We focused mainly on the strategic opportunities around seeking to influence positive creditor behaviour, to address some of the upstream practices that we know have a big impact on people experiencing enforcement. We will reflect further on this discussion in November when we consider an early scoping paper on the draft business plan and budget for 2026/27.
Catherine Brown
Cadeirydd, Bwrdd Ymddygiad Gorfodi