June’s Board meeting was online and the main item on the agenda was complaints.
We started by considering data on our complaints service covering the period from its launch until April 2026. As we expected, performance against our KPIs on timeliness are not where we want them to be and that’s one of the reasons we are prioritising a process and efficiency review this year. In the meantime, the team did report some encouraging progress since new members of the team have joined, particularly around the speed with which complaints are being passed on to investigation and additional measures being pursued at that stage to resolve some cases without needing a full investigation.
We reflected on the number of cases that we are currently upholding following investigation (over 50%) and the fact that we are also finding that the first-tier complaints handling has not been adequate in too many cases. Improving first tier complaints handling is very important – it will help those who complain to get a better and swifter resolution and will also play a key part in managing the ECB’s caseload and containing the costs of the second-tier complaints system to the industry. Put simply, better first tier complaints handling should help to reduce the number of cases flowing through to the ECB. It was therefore encouraging to hear from the team about recent workshops with industry and further plans for sharing learning from our work with complaints teams at firms.
As the numbers of complaints that we have investigated grows, the Board is interested to better understand those firms that are generating disproportionate numbers of both upheld complaints and complaints where the first-tier handling has not been satisfactory. This will help us to target our oversight attention.
We also discussed the first cut of data from the demographic information we have started to capture from those who complain to us. The Board welcomed the response rate of 65%. We also noted the high proportions of complainants who disclosed a disability and wider vulnerabilities. As we get more and richer data in, we will be able to start to correlate demographic data with outcomes from our complaints service, to identify if there are any differential outcomes. We also want to be able to compare the data on demographics of those who are complaining to us with the demographics of those who experience enforcement in general. As set out in our Business Plan, we will be scoping some future work on demographics of those who experience enforcement during 2026/27.
Lastly, the team presented the scope and timeline for our Process and Efficiency Review of the complaints service. Whilst our complaints service is currently delivering high quality decisions and making a positive impact for the public, it is clear that it will need to handle much higher volumes of complaints than we had anticipated. The Board was keen to emphasise the importance of this review being sufficiently bold, focussed on how we can future proof the scheme to handle increasing numbers of complaints without exponential growth in the team. It was encouraging to receive this confirmation from the team, which was reflected in the broad scope of work that was presented and the possible changes being explored.
Board members also emphasised the importance of reflecting the views and experience of those who are complaining to us, as well as working with debt advisors and complaints teams within enforcement firms. The review is now underway and is one of the key projects for the ECB in 2026/27.
Beyond complaints, the Board discussed our increasing concern about missing Body Worn Video. The use of BWV is a fundamental requirement to ensure that people experiencing enforcement are consistently fairly treated, and indeed that enforcement agents are safe. So data from the last data return, highlighting that Body Worn Video was missing from 9% of complaints cases that firms handled is of very significant concern. There is a clear requirement in the ECB’s Standards that BWV must be in place and working during all enforcement and for 1 in 11 cases checked as a result of a complaint to breach that standard is unacceptable.
The team have identified some firms who do much better and others who have even higher levels of missing BWV and will be approaching them directly. We also heard that our complaints team has upheld a number of complaints where BWV is missing.
The Board made clear its expectation that this issue is addressed as a matter of urgency and we are looking forward to a further discussion on the plan to achieve significant improvements in this area when we next meet.
We also discussed plans to exert further pressure on the Government to act on its commitment to introduce mandatory, statutory regulation of the enforcement sector. This is crucial to protect vulnerable people and to ensure a level playing for enforcement firms. It is widely supported and the Government needs to just get it done now, before it runs out of time.
We’re looking forward to visiting Swansea for our next Board meeting, in July.
Catherine Brown
Chair, Enforcement Conduct Board