Vulnerable Customers: Is Your Firm Identifying Who Needs More Support — or Just Assuming It Will Be Obvious?

The FCA's expectations around vulnerable customers have never been more explicit. Under Consumer Duty, identifying, recording, and appropriately supporting customers in vulnerable circumstances is not a discretionary act of goodwill — it is a regulatory obligation with board-level accountability attached.

The FCA's Financial Lives survey consistently demonstrates that the majority of UK adults display at least one characteristic of vulnerability at some point. Yet supervisory findings reveal that most firms still lack the policies, staff training, and operational procedures needed to identify vulnerability reliably and adapt their service delivery meaningfully in response. Having a vulnerable customer policy is not the same as having one that works — and the regulator knows the difference.

In this episode, we examine what a genuinely effective Vulnerable Customer Policy and Procedures framework looks like, how it connects to your broader Consumer Duty obligations, and why firms that treat vulnerability as an edge case rather than a mainstream compliance priority are storing up significant regulatory exposure.

Whether you are a compliance officer, a customer outcomes lead, or a senior manager with Consumer Duty accountability under SMCR, this episode gives you the practical framework to assess whether your current approach is fit for regulatory scrutiny.

We cover:

— The regulatory foundation: Consumer Duty rules, Principle 12, the FCA's Consumer Vulnerability Guidance, and what the four outcome areas require firms to deliver for customers in vulnerable circumstances

— Defining vulnerability correctly: the FCA's four driver framework — health, life events, resilience, and capability — and why a narrow definition creates immediate gaps in your identification process

— Identification in practice: training frontline staff to recognise vulnerability indicators, asking sensitive questions appropriately, and recording vulnerability data consistently and in a GDPR-compliant manner

— Adapting your service: what reasonable adjustments look like across different product types, communication channels, and customer journeys — and how to document that adjustments have been made

— Complaints and vulnerability: how your RCA process should identify whether complaint patterns disproportionately affect customers in vulnerable circumstances

— Governance and oversight: how vulnerability data should feed into management information, board reporting, and your Consumer Duty annual assessment

— SMCR accountability: how personal liability attaches to Consumer Duty failures affecting vulnerable customers and who is in the frame when systemic weaknesses are identified

This episode is essential listening if your firm:

— Has a vulnerable customer policy not reviewed since Consumer Duty implementation

— Relies on customers self-identifying vulnerability without proactive identification procedures in place

— Has no consistent process for recording vulnerability across the customer journey

— Is preparing for an FCA supervisory visit or producing its Consumer Duty annual board report

Resources mentioned in this episode:

Compliance Consultant's Vulnerable Customer Policy & Procedures Playbook is a ready-to-use toolkit for FCA-regulated firms. It provides a structured policy framework, staff guidance, identification and recording procedures, and governance templates enabling compliance and customer outcomes teams to embed vulnerable customer support that genuinely reflects current FCA expectations under Consumer Duty.

Built by qualified regulatory consultants who know exactly what "good" looks like.

Visit complianceconsultant.org to find out more, or call us on 0800 689 0190.

Compliance Consultant — Making Compliance Work.