The High Court Enforcement Officers Association (HCEOA) has welcomed today’s publication of new Vulnerability Standards for the enforcement profession set out by the Enforcement Conduct Board (ECB).
Alan J. Smith, Chair of HCEOA, said: “We welcome the publication of these new Vulnerability Standards from the ECB. A critical point that is really important for everyone involved in the sector to understand is that, under these new standards, identifying someone as vulnerable does not mean that enforcement activity has to automatically stop.
He added: “The Standards state that agents and firms must respond to identifying someone as vulnerable in a way that ‘sufficiently mitigates the risk of that person experiencing foreseeable harm and avoids exacerbating their vulnerability.’ We think that is a key point and we will be working with our members and the ECB over the coming months to help the ECB produce the guidance that will accompany these Standards before they take effect in January 2027.”
There are two linked standards on vulnerability – one for enforcement firms and one for enforcement agents – which will work alongside the wider ECB standards introduced in 2024 and the Ministry of Justice’s existing National Standards, which were introduced in 2014. They take full effect from January 2027.
The ECB is the independent oversight body for the enforcement industry. It was set up with agreement between the enforcement profession and leading debt advice charities including Money Advice Trust, Christians Against Poverty and Step Change.
In September 2025, it published a consultation on its draft Vulnerability and Ability To Pay standards for the enforcement sector. The HCEOA responded to the consultation in detail on behalf of its members, who are all fully trained, qualified and registered High Court Enforcement Officers who are authorised by the Lord Chancellor to enforce High Court Writs.
The new standards have been welcomed by the HCEOA against a backdrop of government inaction on enforcement fees stretching back almost twelve years, despite a commitment at the time for fees to be reviewed annually in line with inflation.
