Siân Berry MP: speeches

Speeches

• 11 Mar 2025 · Public Authorities (Fraud, Error and Recovery) Bill (Tenth sitting) · Hansard source

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  As we have been discussing, schedule 6 and clause 91 make provision that, where all other methods of debt recovery have failed, including the direct deduction order measures we have been discussing, the DWP may apply to a court to have the debtor disqualified from driving. Like the hon. Member for Horsham, I have real concerns about these new powers. I cannot see how this specific novel civil penalty of removing a driving licence is at all appropriate to the particular group of people we are discussing, nor do I see the equivalence to the people being enforced upon by HMRC and the Child Maintenance Service, which have similar powers. Legitimate benefit claimants who are overpaid through error, make a mistake or for any other reason owe money to the DWP are, almost by definition, in need of help. They might often make mistakes or fail to disclose information through an oversight, and their failure to engage with the DWP to date might be due to genuine incapacity and health issues. I am therefore very concerned that there are ineffective safeguards in the court process for these powers. Although the DWP must apply to the court for the disqualification order, the court does not have discretion to refuse unless the debtor needs a driving licence to earn a living or has another essential need for one. It is unclear the extent to which this will protect vulnerable benefit claimants who have not engaged with the DWP due to incapacity, illness or mental ill health, or for whom driving is not essential for their work, but may be essential for their wellbeing or family life. I am not sure that the proposed legislation is clear enough about what will be deemed essential or what will be reasonable for the court to object to. I also have concerns, as outlined a moment ago, that these powers cannot be exercised unless the people concerned have tried every other method, from benefit deductions or deductions from earnings to the direct deductions from bank accounts—the measure we have just discussed, which is extraordinarily intrusive on people’s financial information and privacy. Given that these powers would only be used where it appears that those other powers cannot be, is it not true that they are basically only for when a debtor cannot physically pay back what they owe? In effect, this measure of removing the driving licence is a punishment. It is a poverty penalty for those who do not have the means, despite all the intrusion that Ministers have gone through to establish that, to return what they have been overpaid. I cannot support this power. It is incredibly punitive. I do not think it will create the conditions in which debtors are encouraged to engage with the DWP, but it could create dire consequences for individuals who are already struggling and least able to afford repayments.

• 11 Mar 2025 · Public Authorities (Fraud, Error and Recovery) Bill (Tenth sitting) · Hansard source

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  I beg to ask leave to withdraw the amendment. Amendment , by leave, withdrawn. Clause 89 ordered to stand part of the Bill. Clause 90 Recovery from bank accounts etc Question proposed, That the clause stand part of the Bill.

• 11 Mar 2025 · Topical Questions · Hansard source

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  On Radio 4’s “Today” programme last week, Matthew Ryder KC, who sits as a judge, praised the extreme helpfulness of pre-sentencing reports for passing effective sentences. Will the Secretary of State do as he asks and endorse the importance, value and independence of the Sentencing Council?

• 11 Mar 2025 · Public Authorities (Fraud, Error and Recovery) Bill (Ninth sitting) · Hansard source

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  It is a pleasure to serve under your chairship, Mr Western. I want to raise the comments made by the Information Commissioner in relation to the Bill and the updates to the previous Government’s proposals. I understood that they were more content with this Bill than the previous Bill. They were pleased that it brought data protection more tightly within the measures, and that it talked about data protection in a much more consistent way with the law. They said that the Bill more tightly scopes the types of information that can and cannot be shared. I understand that our debate on clause 85 covered some of those improvements. However, at the end of their comments, the Information Commissioner talked about the review process, and said very clearly that they would like to explore with the Government the role that the Information Commissioner’s Office can play in assisting with the review process. This clause does not set out the different offices and people with whom the independent reviewer needs to liaise in preparing their report. I wondered whether Ministers could comment on their thoughts surrounding that process, and consider setting out in the code of practice or further guidance how the independent reviewer might engage properly with data protection in their review.

• 6 Mar 2025 · Public Authorities (Fraud, Error and Recovery) Bill (Eighth sitting) · Hansard source

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  It is a pleasure to serve under you again, Sir Jeremy. I rise to speak against clause 74 and schedule 3, and to support my amendment 35, which I intend to push to a vote. I also support the two Liberal Democrat amendments, and will vote for those if they are pressed. In short, I am opposed to clause 74 and schedule 3 standing part of the Bill, and to the related powers that apply to the eligibility verification process. These powers do nothing less than bring in a system of disproportionate, mass financial surveillance of millions of people who have done nothing wrong and are not suspected of any wrongdoing. It is of profound concern that these powers are likely to be used at scale to monitor the private bank accounts of people who need the support of society and have done absolutely nothing to arouse suspicion. One of the changes that people wanted to see when they voted out the last Government was a welfare system that treats people with dignity and respect. Sadly and disappointingly, these parts of the Bill are based instead on blame and suspicion of people in need of help, when the bigger issue is unclaimed and underclaimed benefits due to a lack of awareness, complexity in the system and stigma. I asked the Minister in the evidence session whether he would be using these new powers to also help alert people who are underclaiming benefits to what they may be due. The answer was not very clear, but I think it was no, because only the possibility of overpayments and reclaiming those was discussed. I do not want to tweak these proposals—I want to prevent these two parts of the Bill becoming law at all, because they would allow the DWP to require banks and other financial institutions to provide information about claimants of universal credit, pension credit and employment support allowance in order to interrogate their claims of eligibility and entitlement. I assume that every claim would be examined over time. That means a huge new invasion of citizens’ privacy. Currently, if someone is out on the street, the police can only use suspicion-less stop and search on them if they have a section 60 notice in place, which involves setting out a clear reason, identifying a small area and identifying a fixed time for which that would take place. The Bill effectively puts a section 60 notice around every single person who claims these benefits. These people include, disproportionately, people from protected groups—disabled people and older people. This is a real problem; it is discriminatory, unsettling and unfair. On the numbers, around 7 million people receive universal credit, around 1.4 million pensioners receive pension credit, and around 1.5 million get help from employment support allowance. These powers will drag nearly 10 million people directly into a net of intrusive financial surveillance, as well as those appointed to receive benefits on their behalf, including parents, carers, appointed people and landlords. Given that several of these benefits have eligibility requirements based on household income, we are bringing in family members as well. Unsurprisingly, these measures are of huge concern to disability rights, poverty, pension and privacy groups, who are united in their opposition to them. Ideally, I want to see everything struck out, but amendment 35 to schedule 3 would at least mean that more benefits could not be added to the list of relevant benefits by regulations. It would leave in place the ability for Ministers to remove benefits through regulations in future. The hon. Member for Oldham East and Saddleworth (Debbie Abrahams), Chair of the Work and Pensions Committee, set out on Second Reading the risk of damaging trust in and engagement with the DWP for millions of people who might otherwise not claim benefits. I raise that problem because I believe that underclaiming is as much of a problem as fraud and error and should be getting as much attention. On proportionality, it is incumbent on Ministers to come up with a new, more proportionate way to address fraud, where there is reasonable suspicion. I am not against the issue being looked at, but I add that administrative errors are 8% of the problem. They are caused by the DWP’s mistakes and should not result in a need to treat as suspects people who might make errors in their claims due to lack of clarity in or awareness of requirements. It is absolutely right that fraudulent uses of public money are dealt with robustly. To that end, the Government already have significant powers to review the bank statements of welfare fraud suspects. Ministers did not hear me complaining at the new powers to require more information when there is a reasonable suspicion of somebody having committed fraud. This eligibility requirement goes way, way beyond. There are automated decision-making powers coming through in another Bill, which impacts on this Bill and the assurances we have received from Ministers. They say that no automated decisions will be made based on the eligibility verification data alone and that, where potential fraud is identified against those eligibility indicators, cases will be referred to the DWP for further consideration and investigation. However, assurances by the DWP that a human will always be involved in the decision whether to investigate an individual are not set out in the legislation, and the scale and nature of any human input is very unclear, despite its having been promised. Furthermore, as we heard in oral evidence, while assurances about human involvement are also provided for under current data protection law, the Data (Use and Access) Bill currently making its way through Parliament will remove any proper prohibitions on automated decision making. Those must be included in this legislation, in the code of practice or in the regulations. I believe it is for the Government to produce urgent amendments to solve the problem.

• 6 Mar 2025 · Public Authorities (Fraud, Error and Recovery) Bill (Eighth sitting) · Hansard source

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  I will press mine too.

• 6 Mar 2025 · Public Authorities (Fraud, Error and Recovery) Bill (Eighth sitting) · Hansard source

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  I hope the Minister will not take this the wrong way, but I hope that he is able to understand that the stigma that people feel about applying for benefits is partly to do with the attitudes people have towards those who receive benefits. The idea of the Government applying a privacy invasion measure against that cohort of people as a whole feels like discrimination to them. It adds to the stigma; it speaks to the fact that they feel that they are not treated as well as other people in society. They are not believed when they say that they do not have £16,000. Those are all parts of the same package of discrimination, are they not?

• 6 Mar 2025 · Public Authorities (Fraud, Error and Recovery) Bill (Eighth sitting) · Hansard source

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  Does the hon. Member recall me talking about clause 72 and not speaking up about speeding up the electronic getting of information from banks when people are under suspicion? Does he agree that there is a barrier at that point?

• 6 Mar 2025 · Public Authorities (Fraud, Error and Recovery) Bill (Seventh sitting) · Hansard source

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  In general, I very much support the move to make the PSFA an independent body, and the constitution in schedule 2 seems like a good start. However, looking through it I cannot see anywhere how the people appointed as the chair and executive of the PSFA will be subject to a code of conduct; to rules on transparency and registering interests; to requirements relating to compliance with the Nolan principles; and to the oversight of the Advisory Committee on Business Appointments relating to subsequent work after they leave the PSFA. The Minister, who is currently named in the Bill, is subject to all those requirements. There is clear potential for conflicts of interests in the various roles, so it is important that they are put under that regime. Will the Minister be clear about how that will come about and whether that could be added to the constitution if it is not already there?

• 6 Mar 2025 · Public Authorities (Fraud, Error and Recovery) Bill (Seventh sitting) · Hansard source

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  It is a pleasure to serve under your chairmanship again, Sir Desmond. I want to reiterate the points made by the Opposition spokesperson, the hon. Member for Kingswinford and South Staffordshire. It is not good enough to be able to refer only to the official record of the long list that the Minister just read out of what is likely to appear in the code of practice. At this stage of the legislation, we ought to be scrutinising at least a draft. The clause does not include any consultation on a draft code of practice and there are no scrutiny safeguards built into the legislation, so it is wrong to not be looking at the details. In previous debates, I have set out my concerns that although there have been reassurances that this part of the Bill is about major fraud, and that it excludes the Department for Work and Pensions, it is easy to envisage that there may be a scheme of fraud against other Departments that involves defrauding grants that are available to support people claiming certain benefits. That might bring people who are poorer and more vulnerable into a scheme where, according to previous clauses, these penalties may be applied. We need to look at the code of practice in draft form at this stage of the legislation or as soon as possible.

• 4 Mar 2025 · Public Authorities (Fraud, Error and Recovery) Bill (Fifth sitting) · Hansard source

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  It is a pleasure to serve under you today, Mrs Lewell-Buck. I do not support the Conservative amendment. A lot of the discussion in Committee has been about reducing the risk of harm to potentially vulnerable people and people caught up in these frauds, who might not deserve to be punished in any way. I would not support taking out a measure that is there presumably to reduce the consequences of making an error. Therefore, I will not support the amendment.

• 4 Mar 2025 · Topical Questions · Hansard source

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  T7. Expanding UK airport capacity has a very shaky case for economic benefits, because business is not increasing its use of air travel, and the UK sends three times as many tourists out by plane as we welcome in. Will the Chancellor urgently publish her evidence of any net benefits to the economy from airport expansion so that it can be carefully examined?

• 4 Mar 2025 · Public Authorities (Fraud, Error and Recovery) Bill (Sixth sitting) · Hansard source

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  I forgot to make a point earlier about the common practice with penalty notices of offering a person the ability to pay less if they pay sooner, but if they exercise their right to appeal, they lose that discount. That is how penalty notices are often presented. The Minister assured us that people will be able to state in appeals that they are subject to hardship, but that practice effectively negates the point of appealing. Could Ministers introduce a prohibition on offering that kind of fake discount on penalty notices for early payment, so that everybody can exercise their right to a review based on hardship?

• 4 Mar 2025 · Public Authorities (Fraud, Error and Recovery) Bill (Sixth sitting) · Hansard source

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  It is a pleasure to serve under you, Sir Desmond. I have two quick questions for the Minister. I associate myself with the comments about ongoing scrutiny and consultation. I am pleased that the most consequential of these potential new regulations will be subject to the affirmative procedure, but it seems like a lot to not go through a huge amount of scrutiny beforehand. I want to ask about why subsection (2)(c), which relates to whether somebody might suffer hardship, is excluded from the consultation required under clause 37(5). Subsection (2)(f) is also excluded, which is about whether there might be cumulative hardship as a consequence of things done under this law or other laws. The people affected by that, and those who represent people who might face hardship, ought to be consulted on that as well. Is it because the definitions of hardship are scrutinised and well established elsewhere, and we will draw on those definitions when making the regulations, or do we need additional information in this clause or assurances from Ministers that this will happen? Finally, I want to ask about the meaning of the word “Schedule” in subsection (2)(f).

• 4 Mar 2025 · Public Authorities (Fraud, Error and Recovery) Bill (Sixth sitting) · Hansard source

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  I have more serious questions about this part of the Bill than I have had about any other. I question the additional penalty notices: what goals do they have and will they be achieved? I can see that Ministers seek to go beyond simply recovering lost funding, when it comes to issues of error or fraud that results from personal misunderstandings and so on, and that they want to be able to act more quickly and efficiently on slightly more organised defrauding of public bodies. However, I do not see how the Bill helps with the biggest fish, who are taking huge amounts of public money, potentially through fraudulently obtaining contracts, fraudulently setting out work that they did not do, or fraudulently stating the quality of the work they will do or the materials they will use. At the end of chapter 5, the Bill states that if a person has received a fixed penalty, they cannot now be prosecuted. I wonder whether these fixed penalties will be just the cost of doing business for the biggest, most commercial fraudsters, while being potentially disproportionate towards people who may be taking smaller amounts away from the DWP in particular. We received written evidence from the charity Turn2us, whose representatives are worried about the way that the Bill as a whole does not seem to create a clear enough distinction between fraud and error. Turn2us highlights that it might act as a deterrent to people who are more vulnerable, or older, or who would worry excessively about falling foul of these regulations and being accused, on the balance of probabilities, of doing fraud if they make a mistake. There is already stigma attached to claiming things from the Government, which may deter people. On Second Reading, and to some extent during the Committee evidence sessions, we discussed examples of people sharing tips and potentially their own personal experience online, in a way that encourages other people to make misrepresentations towards the Government. These penalty notices are not as well drawn as the measures already considered by the Committee in terms of their potential harms. They are fixed penalties, and the Minister is setting the amounts to try to strike a balance between the poorest people and the highest-level, most organised criminals. I foresee in my future casework people coming to me whose lives started to spin out of control when they were given this kind of penalty notice on top of having to pay back money they had received. The repayment amounts will have been calculated according to what they could afford, but these fixed penalties have fixed deadlines and interest attached. Somebody could make a mistake in the process of dealing with the authorities and be subject to the additional £300; then, if they do not pay that, there are further penalties attached. I worry that this chapter is not very well put together in terms of safeguards on how it might affect people. I might get reassurances in this debate about what the Bill is intended for; of course, if somebody is out there giving intentionally fraudulent bad advice, all the people who they give advice to will not be brought into a mass fixed penalty issued as a result of the investigation. We will avoid that. However, there has already been creeping use of repayments by the DWP in relation to recovering money from people when official error has been made. As stated in the written evidence that we received from the Public Law Project, assurances were made that the DWP does not “have to recover money from people where official error has been made, and we do not intend, in many cases, to recover money where official error has been made.” –– [ Official Report, Welfare Reform Public Bill Committee, 19 May 2011; c. 1019.] That was said to a previous Bill Committee when this process was introduced in legislation, but it is now more or less default practice for the DWP to recover money when official errors have been made. We all, as MPs, have many examples in our casework of people who have got into terrible trouble due to unexpected claims for overpayments made as a result of official error. I have serious concerns about these clauses. I would like to hear more from Ministers about who they are really aimed at, and about whether they will be effective against the big players, or just create potential harm for people who are the smaller fry involved in these kinds of operations.

• 26 Feb 2025 · Grenfell Tower Inquiry: Phase 2 Report · Hansard source

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  I thank the Deputy Prime Minister for, in particular, her comments about the way in which residents were treated. There have been strong recommendations for a review of the Civil Contingencies Act 2004. My former role involved listening to and trying to support the many local community organisations that were dealing with the enormous gaps in the humanitarian response that had been left by the local authority; the problems continued for weeks. Can the Deputy Prime Minister tell us when we will hear about the timing and the format of that review of the Act?

• 25 Feb 2025 · Public Authorities (Fraud, Error and Recovery) Bill (Second sitting) · Hansard source

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  Q I want to ask a couple of questions of clarification. Minister Western, are you open to a negative eventual human rights verdict on this? Many witnesses have said they need answers from the code of conduct, and we know that rights around data protection, privacy and discrimination are engaged by this. If, once we have seen the details of the code of practice, there is a negative verdict on any of those, are you open to changing or withdrawing parts of the Bill, for example by bringing reasonable suspicion to the front of the process instead of the end? Andrew Western: We would need, at that point, to take advice—legal advice, primarily—if there was that level of concern around any human rights impact. I would not want to second-guess, but certainly, in the instance where those views have been put forward and the legal advice suggested that they were valid, then clearly we would need to take appropriate action to ensure that the Bill is legal and satisfactory.

• 25 Feb 2025 · Public Authorities (Fraud, Error and Recovery) Bill (Second sitting) · Hansard source

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  Q Sorry, Chair, the second question I asked about the percentage of error was not answered. What percentage of error do you think would be acceptable, in terms of innocent people being targeted for investigation? Andrew Western: I am not prepared to put a percentage on it. We would have to see what came out. We have done two previous trials on this and we are fairly confident in the mechanisms that are in place. That has underpinned some of the assumptions we have made. We are committing through this process to a test and learn phase so that we can keep errors as minimal as possible. Ideally, I would not want to see any errors at all, but ultimately we have structured this so that, were something to come back as a false positive, as it were, it would not lead to an immediate decision, because it would be passed to a human investigator for further investigation.

• 25 Feb 2025 · Public Authorities (Fraud, Error and Recovery) Bill (Second sitting) · Hansard source

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  Q Those are errors that might be mistaken for fraud, given their outcome of people paying less or— Richard Las: Potentially. But it goes both ways, often. Sometimes people overpay as well. Joshua Reddaway: If you are looking at a particular case, normally the first thing you detect is that it is wrong—the transaction is not correct. You then have to take it to a certain level before you can work out, on the balance of probabilities, what it is. In tax world, is it evasion or avoidance? Then you go down a different route, depending on how you are dealing with it. Obviously, if you want to go for a prosecution, you have to have much more evidence and you have to be beyond reasonable doubt to go there. I think the reason why PSFA often deals with both is that it is at that earlier stage of dealing with prevention, and it is not always clear which one you are dealing with; besides which, we want to stop error as well. My job is to definitely try to stop both, through audit and accountability. I think where it does not make sense for PSFA to get involved is where that fundamental responsibility for correcting the control environment belongs with the Departments. So if you see that as a, “They have done that triaging; they now think that it’s fraud,” you need an enforcement capability and you go down that route, but I would be very disappointed if that meant in that triage process that an error was not being dealt with. Does that explain?

• 25 Feb 2025 · Public Authorities (Fraud, Error and Recovery) Bill (Second sitting) · Hansard source

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  Q I just want to clarify that if someone’s financial situation gets better, you withdraw the payment, but if you saw from the data you are collecting that their situation had got worse and they were starting to face difficulties, you would not seek to send someone in to try to increase the payment. Andrew Western: I am not sure that I fully understood the question, so please come back in if needed. It is clearly the case that if somebody has been receiving benefits that they are not entitled to, for whatever reason, they could end up in a worse financial position as a consequence. That is necessarily the case for two principal reasons. One is that in universal credit all overpayments are reclaimed regardless of the circumstances behind them. That was the policy enacted by the previous Government. The other reason is that they may no longer receive benefits that they previously believed themselves to be entitled to. For instance, if it comes to light that you have £18,000 in your account and there is no mitigating circumstance for that, it would be the case that you would be worse off in overall terms because you would no longer receive that benefit.

• 25 Feb 2025 · Public Authorities (Fraud, Error and Recovery) Bill (Second sitting) · Hansard source

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  Q To follow up on that point, the Bill is called the Public Authorities (Fraud, Error and Recovery) Bill. Do you feel like there is enough built in to identify and deal with errors? As you say, systemic things may be uncovered that are causing errors or losses that are not in fact fraud. Does that get fed back? Would you like to see more in the Bill that systematises that? Joshua Reddaway: Interesting. The reason we always talk about error and fraud together is because it is often really difficult to differentiate between them when you are doing prevention. So, in my job, I am more interested in fraud and error together because I am more interested in how to correct that and stop the money going out. If you are in Richard’s job, as I am sure he will tell you in a second, he is going to be more interested in the one that you can prosecute—to an extent. Richard Las: I am happy to jump in from an HMRC perspective. It is important to understand what the driver is—I think that is absolutely right—and to be able to distinguish between fraud and error. We have estimates for fraud and error in terms of the tax system, which we publish every year. We generate those estimates for a lot of different activity, but partly they are the result of our own inquiries, so we are analysing what we do and what we see. We make a judgment—is it fraud, is it error?—and we work out what is going on. Absolutely, you have to look at the underlying reasons, so if there is an error, a repeated error, you ask what is going on there—what is the cause of it? Certainly, as we develop our business in HMRC—especially with people filing online—we are very much looking to prompt people so that they can get the right answer. Those of you who do self-assessment hopefully will see that yourself—“Are you sure? Is this information correct?” That really does help in reducing errors—the simple errors that people might make, because it is complicated.

• 25 Feb 2025 · Public Authorities (Fraud, Error and Recovery) Bill (Second sitting) · Hansard source

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  Q Disabled people who receive direct payments have expressed some concern that there can be underspends and that these can build up. They have asked for a particular account to be ringfenced for that, and essentially not looked at in relation to these measures. Is that feasible? What is your lead time for knowing that you would need to do it? Would it need to go into the Bill initially? Eric Leenders: It would always be within the gift of a consumer to open a separate account. They can then ask for the benefit to be paid into that account. There might be a risk, from a wider perspective, that potentially attorneys and landlords might no longer want to receive benefits directly because of the potential admin burdens through this Bill. I flag that as a consideration. I do not think it is necessarily a show-stopper but certainly it is something that I think from a vulnerability perspective we need to be alive to, because that might be an additional responsibility on a vulnerable person, for example, to pay the rent.

• 25 Feb 2025 · Public Authorities (Fraud, Error and Recovery) Bill (Second sitting) · Hansard source

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  Q Do you have anything more to say about what the unintended consequences of the Bill might be? Jasleen Chaggar: We are really concerned about the unintended consequences of the Bill. We appreciate that there has been an effort to tackle fraud and error, which is a serious problem, but we also have to consider the adverse and unintended consequences. One of those is the algorithmic error that can occur when automated systems are used on a population-wide scale. If the algorithms are scanning the bank accounts of 10 million people, an error rate of just 1% will result in 100,000 cases where innocent people are wrongfully investigated. We are also really concerned about the human backstop element. The DWP has assured us that there will be human involvement in any investigations on the back of receiving this data, but when you receive such a deluge of information from the banks, that calls into question whether the human involvement will be meaningful. The impact assessment acknowledges that by saying that we might have to slow down the rate at which we receive all this data from banks. We are very concerned about the false positives, and about the devastating effects that they would have on the lives of the individuals who are wrongfully investigated. Benefits recipients, who are already subjected to burdens in terms of documentation requirements, will find themselves subjected to an investigation by the DWP. We have heard from dozens of disability rights and elderly rights groups about the anxiety and stress that this will cause. Also, when benefits recipients are under investigation, they can find that their benefits are suspended, meaning that they will not have the money to pay for food, medical bills or heating bills. So the equality impact also has to be considered, and we have not actually seen an equalities impact assessment for the Bill either, which is a concern.

• 25 Feb 2025 · Public Authorities (Fraud, Error and Recovery) Bill (Second sitting) · Hansard source

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  Q To follow up directly on that, the Government have not really been clear yet which further benefits might be added to the workload in future. Are you happy that this is left open in the Bill? Daniel Cichocki: I do not think we take a view on the scope of individual benefits for which this is applied. The key principle for us is that where there are changes to the eligibility criteria, we are required to check that there is proper public consultation around those changes and an appropriate implementation period for any of those changes, and that those changes are not too frequent. As an industry, we have to build a system to run these checks every time, and every change will have to be built and tested. For us, it is more about the principle of the frequency and appropriateness of the changes. The broader debate around what is in scope is not one we have taken a view on.

• 25 Feb 2025 · Public Authorities (Fraud, Error and Recovery) Bill (Second sitting) · Hansard source

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  Q Are there any other issues in your consumer duties, particularly your duties towards vulnerable account holders, that you have raised with the Government? The Minister has helpfully asked you that question in general terms, but I thought there may be other issues. Going back to Daniel’s earlier comment, can you clarify that you do not yet have a clue regarding the volume of requests? Have you been given some sort of estimate by the Government? Daniel Cichocki: Let me take that first. The Government set out two broad criteria pertaining to the eligibility verification measure: the capital check and the check against abroad fraud, through assessment of transactions abroad. It is difficult at this stage, because the industry has not undertaken any detailed collective analysis of the criteria against the current book of customers. That work has not yet been done. We anticipate it being done through the development of the code of practice, but key for us is understanding exactly what criteria we will be required to run, and then banks can start to build an assessment of how that looks against their current book. That detailed work has not yet taken place.