April 3, 2024


by: kiran


Tags: "Regulation"

Vulnerable Customers: Have you got their backs?

The FCA wants to ensure that customers in vulnerable circumstances are receiving the same quality of outcomes as other customers.

The key aims of this review will be to:

  • Evaluate how well firms understand and address the needs of these customers.
  • Determine firms’ comprehension of consumer needs.
  • Assess staff skills and capabilities.
  • See how product and service design consider the needs of vulnerable customers.
  • How communications are adapted to consider those in vulnerable circumstances.
  • How customer service is considered when dealing with vulnerable customers.


The review will assess a variety of vulnerability areas, including age-related concerns, those in financial difficulties, periods of stress (e.g. bereavement) and health related concerns. The FCA says help to better understand whether more vulnerable individuals are receiving satisfactory outcomes.

To carry out the review, the FCA plans to conduct consumer research and seek feedback from both firms and consumer representatives.


The FCA plans to share its findings by the end of the year and so the review will take place throughout 2024.

What Firms need to consider:

Firms should have already considered vulnerable customers in the work they have been doing around the Consumer Duty. This recent announcement by the FCA sends a clear message that firms need to ensure they have considered all areas of customer vulnerability as part of their preparation for the Consumer Duty and that such systems and controls are now embedded within their firm’s processes.

Firms should be able to identify vulnerable customers and ensure that their outcomes are no less favourable than non-vulnerable customers. You should consider how you would be able to evidence this to the FCA, including demonstrating the quality of the management information you receive.

If you would like an independent review of your approach to vulnerable customers or need assistance in reassessing your systems and controls in relation to this subject, Padda Consulting can support you. Please feel free to contact us should you require any assistance.