The Public Authorities (Fraud, Error and Recovery) Act 2025 which became law in December 2025 is currently going through its “Public Consultation” stage regarding a “Code of Practice” for the terrifying Civil Penalties Powers aspect of that Act including banning people from driving, dipping their bank accounts etc, based on the Minister for the Cabinet Office being satisfied, on the balance of probabilities, that someone committed fraud.
That is due to be completed on 27th Feb 2026, and then within 12 weeks from that date the Government will respond. As such, there will be no Government instigated enforcement action using that law, until it introduces its Code of Practice as per those dates and schedule.
Due to Lenders acting weird recently, for example refusing to take part in the BBL Voluntary Repayment Scheme and other irregularities, that I am monitoring, there are now serious legal questions to be answered as to whether these new Government powers will or will not be used against some or even all BBL blaggers.
If not, then it will be left to the Insolvency Service in conjunction with HMRC, Companies House and the Public Sector Fraud Authority to go it alone and look for non-BBL related wrongdoing committed by, for example, LTD Company Directors, and go after that, which will then allow for the actual BBL wrongdoing to be investigated and then punished.
One of the problems is hidden in the BBL Guarantee Agreement above, that states: “Save as many be expressly agreed between them from time to time, neither the Lender or Guarantor will, as a result of the participation in the Scheme, (i) be (or have the authority to act as) agent for the other or (ii) be (or be treated as being) in a fiduciary relationship to the other.” Some Lenders do not want to do anything to put at risk their BBL Guarantee, and as such do not want the Government acting on their behalf as BBL debt collectors or BBL enforcement officers.
Below is the final report and recommendations of Tom Hayhoe, the Covid Corruption Fraud Commissioner (who left his post on December the 2nd). He has, for the 180,000+ of you with a Strike Off blocked due to an unpaid BBL, put forward a solution, which will allow many of those Companies, whose Directors did nothing wrong, other than not making it through the pandemic to be dissolved, with the BBL being written off, which is based on the solution I gave him, and funding has been allocated to make it live as soon as possible. I am chuffed he listened, you can thank me for that! Also the Covid Inquiry have been looking at BBL’s:
Moving into 2026, the new Public Authorities Fraud Investigation and Enforcement Service are going to be using some imaginative initiatives to bring to justice anyone they know committed any type BBL wrongdoing that their data-sharing exercises have uncovered, using operational efficiencies for trial by the Insolvency Service.
Such as Directors who have pulled any stunts with their LTD Company or not paid their taxes etc this will be achieved by the Insolvency Service using the “stunts pulled” or “non payment of taxes” as an excuse and an indirect way to get the BBL wrongdoing brought to light and punished by applying to the High Court for a winding up order and then seeking compensation orders in favour of the company’s creditors against any Director who ultimately is disqualified for BBL related wrongdoing, which is fully uncovered and confirmed during liquidation. Here are some very recent real life examples:
Other initiatives will include action against those who over-egged their turnover to get a Bounce Back Loan and those who misused the funds. Those initiatives will operate on a ‘test and learn’ basis: gathering data to discover how best to reclaim BBL funds. The over-egging of turnover to get a BBL and the misuse of BBL funds is much higher than initial official Government estimates suggested and has been confirmed due to enhanced data sharing and A.I. analysis exercises.
However, Lenders have lobbed a huge legal spanner into the Governments aim of recovery action on Bounce Back Loans. The Commissioners report ever so slightly hints at that in a roundabout fashion, when he states “the loans are ‘owned’ by the commercial lenders” so 2026 will be an interesting time for all concerned….
The helpline will be open over the Christmas and New Year Period as it is every day of the week. If you or anyone you know is in a bad place, worrying about an unaffordable BBL or any Bounce Back Loan related worries or concerns, give them my number and get them to give me a bell. If you are in a position to help me be there for everyone, please consider making a donation or if you haven’t yet done so, please subscribe to the website, I can only be here morning, noon and night with your support. All the Best, Mike
Please scroll down the page to find all the latest news and information about the BBL Scheme and the upcoming enforcement action, read and digest everything and in order. The Covid Corruption Commissioner left his post on December the 2nd 2025 and has presented Parliament with additional recommendations for rounding up and punishing BBL Blaggers and suggestions for allowing the write-off of legit BBLs that cannot be repaid.
Duncan Beach, previously the Managing Director, Global Head of Risk & Compliance Transformation at HSBC during the time the bank kept quiet about bugs, defects and errors in their BBL application platform, and the bank that has been ordered to remove unfair BBL related CIFAS fraud markers from business owners and the bank that didn’t implement the duplicate database causing 1,000’s of duplicate BBLs to be issued by multiple other Lenders has been appointed as the new Chief Executive of the Insolvency Service and is due to start in January. Quite remarkable!
Talking of HSBC, a Company with links to Sarah Ferguson the ex-Duchess of York which had a Bounce Back Loan is now in Administration, fortunately the amount not paid back and due to be picked up by taxpayers isn’t as big as the defaulted taxpayer backed loan Carole Middleton the mother of Catherine, the Princess of Wales left unpaid.
Most weekdays, people get banned from being a Director of a Company, or Sole Traders and individuals get Bankruptcy Restrictions Orders for BBL related mischief, some people find themselves before a court and ultimately locked up for BBL fraud, and in most cases it is their own actions that have seen them being punished.
Conversely some people get compensated or their BBLs written-off or reduced in value when complaining about unfair treatment by Lenders or due to irregularities with their Bounce Back Loan, here are the latest outcomes of people in those three categories:
The Government, over the last few years, by using various methods including but not limited to matching BBL application forms with Company Accounts or Self Assessments have worked out who has blagged a Bounce Back Loan, and have compiled a naughty list of those who will be chasing in 2026 and beyond. This is how they compiled their naughty list:
It is of course due to the number of people who took the biscuit with the Bounce Back Loan Scheme such as the random ones featured in the articles below, that rattled Rachel Reeves, who before the election promised she would take on a Covid Corruption Fraud Commissioner and seek his guidance on how to go after anyone and everyone who blagged a BBL in one way or another.
It soon dawned on the Covid Corruption Commissioner that way more people had blagged a BBL than first thought and as such he devised a way to try and get the number of people on the naughty list reduced.
That is when the Voluntary Repayment Scheme was dreamt up. That scheme was intended to push/urge/nudge people to repay in full or set up a repayment plan on a dodgy BBL they got. Below is how it was launched on the 12th of September 2025, but keep on reading to discover what quickly went wrong with that scheme.
Once the BBL Voluntary Repayment Scheme was up and running, word soon filtered back to me some Lenders were messing people about and refusing the set up repayment plans and others wouldn’t even allow people to pay back in full a BBL they blagged.
I then set about writing to Lenders asking them what they were offering by way of the Voluntary Repayment Scheme, and some of their replies contradicted the initial aims of the Scheme. The Government then went into panic mode and released guidance of the scheme, 56 and then 76 days after the launch, which was a watered down, heavily diluted set of aims and rules which offered people nothing at all.
Whilst the Voluntary Repayment Scheme was up and running, the Public Sector Fraud Authority tested out a pilot by writing to a modest number of BBL blaggers, telling them we know what you have done, now here are your options.
Below you will find more information on that pilot and a copy of the letters they sent out along with details of just how successful a very early pilot of the upcoming enforcement action went on.
The ultimate aim of the Voluntary Repayment Scheme is to get people to repay a dodgy BBL in full, but that isn’t a reality for most people, but some are setting up a repayment plan with their Lender, before enforcement action begins. Their logic being, that tucked away deep in the Public Authorities (Fraud, Error and Recovery) Bill it says “the Bill contains measures to provide the PSFA with the power to recover debt in relation to funds that a public authority is entitled to recover and which, following a PSFA investigation into suspected fraud, were obtained fraudulently or through error. The PSFA will initially seek voluntary repayment of debts through affordable and sustainable repayment plans”.
The Bill was signed into law by Royal Assent on the 2nd of December 2025, it gives extraordinary powers to the Government to retrieve funds from anyone who blagged money from the Public Purse, you can read more on that in the articles and guides below:
Once the Voluntary Repayment Scheme ends on the 31st of December 2025, the Cabinet Office, Public Sector Fraud Authority, Insolvency Service and others are going to set about chasing and trying to bring to justice everyone who has blagged a Bounce Back Loan.
They will be aided in such due to the new Directors I.D. Verification Scheme launched by Companies House and the passing into law of the Public Authorities (Fraud, Error and Recovery) Bill. Below are some more recent articles that I have compiled that you may find of use.
The latest Bounce Back Loan data dump came my way today, the 28th of November 2025, which reveals that to date a total of £11,417,650,000 has been paid out to Lenders via the Government Guarantee with another £221,660,000 waiting to be paid out and some £170,760,000 in Guarantee claims waiting to be put in. To date, 67,448 BBLs are in arrears and 433,115 are now in default.
Bugs, Errors and Defects on BBL Lender platforms/software has seen them having their Guarantees yanked on some 14,063 BBLs worth a mind-blowing £497.84million, it’s similar to Post Office Horizon scandal as many people could have been convicted due to those often unreported bugs, defects and errors, (some possibly have been) but spotted them and have managed to have their BBL’s written off by noticing them and complaining.
