Our Work
Vulnerability and Ability to Pay Standards
Overview
As part of the ECB’s commitment to ensuring everyone subject to enforcement action is treated fairly, we produce Standards and guidance for ECB accredited enforcement firms and those who work for them. We published our first Standards for Enforcement Firms and Agents in October 2024, which you can view here:
Standards – enforcementconductboard
In March 2026 we published an additional set of Standards covering firms and agents’ approach to vulnerability. These Standards will come into force in January 2027.
Standards on Vulnerability for Enforcement Agents
Standards on Vulnerability for Enforcement Firms
The Standards raise the bar for the entire industry. At their core, they do two things:
- Improve the way that enforcement firms and agents identify and respond to vulnerability
- ensure repayment plans are sustainable and safe when people cannot repay in full.
We have set out clear, practical steps that firms and agents must follow. These steps ensure vulnerable people are not harmed by the enforcement process, or pressured into payment plans that leave them unable to meet essential living costs.
The Standards follow a year of engagement with firms, agents, debt advisers, creditors, and people with lived experience. Their voices have shaped the final approach and we are deeply grateful for their input.
Implementation
The Standards take effect in January 2027. Firms must produce implementation plans by June 2026 to show how they, and the agents they employ, will prepare for this.
Over the summer, the ECB will work with stakeholders to produce supporting guidance, including practical examples. We will share more information soon on how you can support the developement of this guidance.
When the Vulnerability Standards come into effect in January 2027 we will merge them with the existing Standards, so that there is just one set of Standards for firms, and one for agents. The numbering of the Vulnerability Standards reflects this.
Consultation
Getting the new Vulnerability Standards right is critical to achieving our mission and ensuring that people experiencing enforcement in vulnerable circumstances do not sustain unfair or worse outcomes.
We have been working to develop the Vulnerability Standards since April 2025. We carried out extensive engagement on our initial thinking, including workshops with firms, agents, people who have experienced enforcement and debt advice organisations, and a formal consultation. The final version has been shaped by this input and is noticeably different to earlier drafts.
You can find the (now closed) consultation here and a report summarising the consultation responses below.
Consultation on ECB Standards for Enforcement Work – vulnerability and ability to pay
As part of our engagement, we asked research agency Revealing Reality to run focus groups with Enforcement Agents and, separately, with people who have experienced enforcement. Their views on how the Standards should work were considered as part of our wider consultation and engagement. You can download the full reports from Revealing Reality below.
Report on enforcement agents’ perspectives
Report on reflections of people with lived experience of enforcement.
For any questions on the new Standards please email contact@enforcementconductboard.org