Thematic Reviews

From time to time, the ECB may undertake a Thematic Review of a specific operational area. These reviews are typically triggered when a particular risk or regulatory issue is identified that warrants further investigation across the industry.

In 2025, the ECB identified a serious breach of the Taking Control of Goods (Fees) Regulations 2014 at an accredited enforcement firm. The breach involved the improper charging of multiple enforcement fees in cases that should have been linked and handled together.

We launched a sector-wide Review to examine how fees are applied in practice. The review found no evidence of widespread or systemic overcharging among the firms visited. However, it identified inconsistencies in how firms interpret and apply the regulations, including: 

• how cases are identified and linked
• whether cases should be linked across different creditors
• when enforcement fees are triggered
• how and when sale fees are applied

We concluded that clearer Standards for fee-charging are required and we will consult on new Standards in 2026, for implementation in 2027.