Insights ¦ Managing Vulnerability in Insurance Roundtable Summary Report

Key Take Aways

1. Effective vulnerability management requires a proactive, organisation-wide approach that integrates identification, support, and outcome monitoring at every customer interaction.

2. Embedding vulnerability considerations into product design, underwriting, and service processes is essential, yet current practices remain uneven across firms.

3. Leadership accountability is critical; senior executives must take direct ownership of outcomes for vulnerable customers instead of delegating to compliance teams.

4. Data quality, sharing, and utilisation are significant challenges; granular, standardised data with a clear taxonomy underpin effective support and continuous improvement.

5. Many firms lack the comprehensive management information needed to link vulnerability identification with tangible customer outcomes.

6. Organisations must shift behaviours to foster a culture where customers feel safe disclosing vulnerabilities, supported by transparent communication of the reasons for data collection.

7. Training gaps persist, particularly for non-frontline staff; ongoing, embedded training—including innovative methods like VR—can enhance understanding and empathy.

8. A cultural shift towards genuine customer-centricity is necessary, with boards actively engaging in customer experience and outcome reviews to reinforce importance.

9. Clear, sector-wide standards that set baseline expectations for vulnerability processes, training, service modification, and outcome monitoring are needed to bridge the current implementation gap.

10. Learning from other sectors—such as gambling, personal finance, and utilities—can inform best practices in real-time behaviour analysis, data sharing, and registration systems.

11. The FCA’s Vulnerability Review highlights progress in frontline support but identifies persistent weaknesses in processes, data usage, and outcome embedding.

12. The CII commits to developing practical guidance and facilitating sector-wide collaboration to improve support and trust for vulnerable customers.

Key Statistics

• Only 19% of vulnerable customers feel encouraged to disclose their circumstances.

• Just 11% of insurers have trained non-frontline staff on vulnerability, despite it being a senior management and certification regime (SMCR) responsibility.

Key Discussion Points

• The importance of moving beyond disclosure towards delivering consistent, meaningful support throughout the customer journey.

• The necessity of adopting a structured approach to vulnerability, including identification, understanding impacts, providing support, and outcome monitoring.

• Challenges posed by siloed data systems and GDPR concerns, and the potential for GDPR-compliant solutions rooted in customer consent.

• The critical role of active, empathetic listening and a shift away from rigid scripts to foster trust and better support vulnerable customers.

• The persistent training gaps across all staff levels and the potential for innovative methods such as VR to improve empathy and understanding.

• The need for cultural change, with boards demonstrating accountability and embedding vulnerability considerations into governance and strategy.

• The benefit of sector-wide standards to set clear, adaptable benchmarks for vulnerability management.

• The value of cross-sector insights from utilities, gambling, finance, and claims sectors to improve practice and data sharing frameworks.

• The FCA’s findings that progress remains inconsistent, with strengths in frontline training but deficiencies in embedding vulnerability into product design and outcomes measurement.

• The importance of establishing a clear causal link between vulnerability identification and improved customer outcomes for continuous improvement.

• The potential of real-time behavioural data analysis and independent registries, as used in other sectors, to enhance proactive vulnerability support.

• The CII’s commitment to evolving guidance and sector collaboration to place vulnerability management at the heart of ethical professional practice.

Document Description

This article is a summary report of a roundtable convened by the Chartered Insurance Institute (CII) focused on managing vulnerability in the insurance sector. It captures insights from regulators, sector leaders, academic experts, and consumers on current challenges, opportunities for improvement, and best practices. The report highlights key findings from the FCA’s vulnerability review, real customer experiences, and discussions on systems, data, behaviours, training, and cultural change necessary to deliver better, fairer outcomes for vulnerable customers. It also outlines next steps, including the development of actionable guidance and sector-wide standards to embed vulnerability considerations into everyday business practice.