Bregusrwydd

Our approach to vulnerability

The ECB wants everyone experiencing enforcement action to be treated fairly. We know that for some people who are in vulnerable circumstances, the process can be particularly distressing and potentially result in them experiencing some types of harm. Our Standards – which come into force in 2027 – explain what accredited enforcement firms and their staff must do to identify vulnerability, understand how it may affect a person, and respond appropriately. They also cover ability to pay, so that repayment arrangements are sustainable and do not leave people unable to meet essential living costs.

Why vulnerability matters

Enforcement action can take place at an already difficult time when someone’s circumstances may affect their ability to understand what is happening, communicate with a firm or agent, make decisions, manage the process or afford a payment. If those circumstances are not recognised and taken into account, enforcement action can cause avoidable harm or lead to unfair outcomes.

Our approach is designed to make sure firms and agents take practical steps to recognise vulnerability and respond to each person’s needs.

What we mean by vulnerability

Vulnerability is not a fixed label or a single list of circumstances. People may be vulnerable because of a health condition, disability, bereavement, financial difficulty, language or communication need, a stressful life event, or a combination of factors. Vulnerability may be temporary, ongoing or change over time.

What matters is how a person’s circumstances affect their ability to engage with enforcement action and whether the process could place them at risk of harm or an unfair outcome. Our Standards ensure that firms and agents consider the person’s individual circumstances rather than make assumptions.

How vulnerability might affect people

In practice, vulnerability may mean that someone:

• finds it difficult to understand information, remember details or make decisions;
• needs information explained in a different way or more time to respond;
• has difficulty communicating by telephone, in writing or in person;
• is unable to deal with enforcement action without help from another person or an advice organisation;
• may be at risk of physical, emotional or financial harm if enforcement continues without adjustments; or
• cannot afford to pay in full or agree a repayment plan without falling behind on essential household costs.

The Standards require firms and agents to look for signs that someone may need support, ask appropriate questions, record and share relevant information safely, and make reasonable adjustments to their approach.

Depending on the circumstances, firms, agents and staff may need to change how they communicate, allowing more time, involving an authorised third party, signposting to independent advice, pausing action or assessing whether a repayment arrangement will enable someone repay their debt while still meeting their essential needs.

It is important to note that vulnerability does not automatically mean the enforcement process has to stop. Many people in difficult circumstances are able to engage with the process, with appropriate support or adjustments put in place where needed.

How we developed our approach

We developed our vulnerability standards through research, consultation and extensive engagement in 2025/26. This included workshops and discussions with enforcement firms, agents, creditors, debt advice organisations and people with direct experience of enforcement. The feedback we gathered, along with the responses to our formal consultation helped us test and refine our initial proposals. We set out some of the key changes that we made to our final Standards in our consultation response.

Consultation on ECB Standards for Enforcement Work – vulnerability and ability to pay

Vulnerability Standards for Enforcement Work: consultation response

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We also commissioned Revealing Reality to hold separate focus groups with enforcement agents and people with lived experience of enforcement. This research gave us a fuller understanding of how vulnerability is experienced and managed in practice, and the findings informed the Standards alongside the wider consultation.

Research report: enforcement agents’ perspectives

Research report: reflections of people with lived experience of enforcement

Read the Vulnerability Standards

The Vulnerability Standards sit within the ECB’s general Standards for Firms and Standards for Enforcement Agents. They will take effect from January 2027.

ECB standards for firms

ECB standards for agents