Insights ¦ Firms’ treatment of customers in vulnerable circumstances – review

Key Take Aways

1. There is a recognised need to support customers in vulnerable circumstances, given their susceptibility to harm and diverse needs.

2. The FCA conducted a comprehensive review evaluating firms’ actions, outcomes for customers, and the relevance of existing guidance under the Consumer Duty.

3. Many firms demonstrate positive practices and exhibit increased awareness, culture change, and tailored support towards vulnerable customers.

4. Consumer research indicates that, despite improvements, consumers in vulnerable circumstances, particularly those with multiple vulnerabilities, continue to experience poor outcomes.

5. The existing FCA guidance remains relevant and valuable; there is no immediate need for revision or additional regulatory requirements.

6. Stakeholders emphasised the importance of practical case studies to help firms implement guidance more effectively.

7. The FCA’s approach included qualitative and quantitative consumer research, surveys of over 1,500 consumers, and responses from 725 firms.

8. There is a recognised positive impact of the guidance on firm culture and operations, especially regarding understanding drivers and characteristics of vulnerability.

9. Firms find the clarity around vulnerability characteristics and definitions helpful in shaping their approaches.

10. Ongoing engagement with industry and stakeholders is essential for continuous improvement in outcomes for vulnerable consumers.

11. The FCA intends to continue using examples of good practice and will incorporate outcome monitoring in its broader Consumer Duty work.

12. Regular collaboration with industry is vital to address areas identified as challenging, ensuring sustained progress in supporting vulnerable customers.

Key Statistics

• Consumer survey sample size: 1,500 participants.

• Responses analysed from 725 firms for the multi-firm survey.

• Follow-up information requests sent to 29 firms across 12 markets.

• Specific data and detailed analysis available in the report linked within the article.

• The FCA’s public publication dates: First published on 07/03/2025, last updated on 07/03/2025.

Key Discussion Points

• The importance of acting to deliver good outcomes for customers in vulnerable circumstances.

• The role of FCA guidance alongside the Consumer Duty in shaping firm practices.

• Evidence of positive change in firm attitudes, cultures, and practical implementation.

• The ongoing challenges faced by consumers with multiple vulnerabilities and poor outcomes reported.

• The value of the FCA’s definition of vulnerability and its drivers and characteristics.

• Stakeholders’ views reaffirm the usefulness of current guidance but highlight the need for more case studies.

• The effectiveness of the guidance in fostering understanding and supporting practical application.

• The importance of continuous monitoring of outcomes for vulnerable consumers.

• The FCA’s commitment to not revising the guidance but to leveraging good practices and lessons learnt.

• The significance of industry engagement and cooperative efforts in closing gaps.

• The role of case studies and industry examples in fostering continuous improvement.

• The focus on outcomes across multiple sectors and the potential for further targeted investigation.

Document Description

This article reviews the FCA’s comprehensive assessment of how financial services firms support customers in vulnerable circumstances. It details the methodology, key findings, stakeholder feedback, and future steps. Emphasising the ongoing relevance of existing guidance and the impact of the Consumer Duty, the document highlights areas of progress, challenges, and the FCA’s commitment to enhancing outcomes for vulnerable consumers through continuous industry engagement and best practice sharing. It serves as a strategic overview for senior managers seeking insight into emerging industry practices and regulatory expectations.