This in-depth discussion with Chris Fitch, a leading authority on consumer vulnerability, discusses the evolution of vulnerability thinking in financial services over the past two decades.
The conversation explores how regulation, culture, innovation, and operational practices have matured in the UK, placing it as a global leader in this space.
Chris reflects on the transition from broad definitions of vulnerability to more actionable support needs, highlights the critical role of data and staff capability, and outlines next steps including data portability, sector-wide collaboration, and a greater focus on measurable outcomes.
Find out more about Chris Fitch-> Here.
Key Take Aways
- The UK has experienced a “vulnerability decade” with a sustained focus on consumer vulnerability across financial services, led significantly by the FCA since 2014.
- Firms are increasingly moving from recording vulnerability “drivers” (e.g. mental health, life events) to identifying and acting on specific “support needs”.
- There is strong international recognition of the UK’s leadership in vulnerability policy, with interest from countries such as Norway, Australia, and Spain.
- Regulatory backing has been crucial in sustaining momentum, particularly following the 2008 financial crash.
- Staff engagement and cultural change within organisations have been instrumental, with frontline staff embracing the opportunity to support customers more effectively.
- Firms have matured in their approaches—simplifying legacy tools, operationalising charity-developed methods, and embedding vulnerability frameworks across functions.
- Despite progress, measuring the outcomes and effectiveness of interventions remains a key gap.
- Standardisation of support need categories and lexicon is critical to enabling smart data sharing and interoperability across firms.
- There is a growing call for honest, transparent communication from firms on what support they can and cannot offer.
- Inclusive design is embraced in principle but needs to be better understood and implemented based on real customer needs, not assumptions.
- Collaboration across sectors is essential—no single firm can fully support a vulnerable customer in isolation.
- Return on investment (ROI) in vulnerability initiatives must be clearly demonstrated to ensure long-term sustainability and business alignment.
Innovation
- Support Needs Framework: Moving from labels of vulnerability to clearly defined and standardised descriptions of the support required.
- Tell Us Once Mechanisms: Exploring centralised systems where customers can disclose support needs once and have them shared across multiple firms.
- Digital Identities and Wallets: Potential use of trust frameworks and digital tools to control and share vulnerability-related data securely and efficiently.
- AI in Training: Simulating vulnerable customer scenarios using AI to train staff in safe, realistic environments.
- Aggregated Accessibility Data: Concept of “accessibility descriptors” for products to allow comparison and better consumer choice.
- Cross-sector Registers: Linking priority service registers across financial services, energy, telecoms, and delivery sectors for consistent support.
Key Statistics
- £26,000: Debt run up by a customer with schizophrenia despite a £6,000 income.
- 6–7 weeks: Annual time cost for a customer with ADHD and bipolar disorder disclosing their needs repeatedly across firms.
- £234 billion: Estimated value of the “purple pound” – the spending power of disabled people and their households.
- 10 million: Number of Monzo customers referenced in the conversation.
Key Discussion Points
- The evolution of vulnerability understanding—from medical and social contexts to essential services.
- The pivotal role of the FCA in embedding vulnerability into regulatory frameworks post-2008.
- The importance of institutional memory and documenting sector progress.
- Shifts in organisational culture, especially in debt collections, from transactional to empathetic engagement.
- The influence of “loud voice” charities and the risk of overlooking less-publicised vulnerabilities.
- Benefits and limitations of inclusive design principles in practice.
- Development and operationalisation of tools such as the TEXAS disclosure model.
- The growing interest in standardising support needs terminology.
- Cultural shifts enabling consumers to self-identify as vulnerable more openly.
- The need for firms to articulate both the support they offer and their limitations.
- Challenges of demonstrating outcomes and ROI to secure internal investment.
- The competitive advantage and customer loyalty that come from transparency and inclusive service design.
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