Vulnerable Customers – Taking Practical Action

In its recently updated guidance on the fair treatment of vulnerable customers, the FCA focusses on the actions firms should take when dealing with vulnerability.

Covid-19 has undoubtedly exacerbated incidences of vulnerability in the UK. The FCA’s Financial Lives coronavirus survey, which was carried out in October 2020, shows that more customers find themselves in vulnerable circumstances as a result of the pandemic. 53% of adults now display a characteristic of vulnerability which is an increase of over 3 million since February 2020. It is also worth bearing in mind that many of these individuals could have multiple characteristics of vulnerability.

The effects of the pandemic have been wide-reaching, impacting not only on people’s physical and mental wellbeing, but also on their finances, due to furlough, unemployment etc.

What should firms be doing?

The FCA wants to “drive improvements in the way firms treat vulnerable consumers and bring about a practical shift in firms’ actions and behaviour.” Firms should seek to understand the needs of vulnerable customers and make any changes necessary to the way they do things.

Staff should be trained so that they have the skills and capability to recognise and respond to characteristics of vulnerability appropriately.

When it comes to taking practical action, the FCA identifies three key areas that firms should focus on:

  • Product and service design
  • Customer service
  • Communications

Let’s look at each in more detail…

Product and service design

Firms need to consider the potential positive and negative impacts of a product or service on vulnerable customers, and should design products and services that avoid any potential harmful impacts.

Vulnerable customers should be taken into account at all stages of the product and service design process. This will include:

  • idea generation;
  • development;
  • testing;
  • launch; and
  • review

Any products and services should meet the needs of vulnerable customers.

Customer service

Systems and processes should be set up in a way that supports and enables vulnerable consumers to disclose their needs, and it’s important that staff are able to spot signs of vulnerability – such as, but not limited to, changes to payment behaviour, agitation or requests for information to be repeated.

Customer service should be delivered in a way that is flexible, depending on the customer’s individual needs.

Customers should also be made aware of the support available to them, including signposting to relevant third parties and specialist support services. 

Firms should put in place robust systems and processes which support the delivery of good customer service – and should be able to note and retrieve information about a customer’s needs.


All communications and information about products and services need to be understandable for customers.

Firms should consider how they communicate with vulnerable consumers. Do they communicate in a way that meets their customers’ needs?

Offering multiple channels of communication, where possible, is important. For instance, a sight and hearing impairment can make some communication channels unusable, so accessibility needs to be considered.

Finally, the FCA’s view is that firms should monitor and evaluate their treatment of vulnerable customers. In doing so, firms can identify what in their approach is working, and what might need some adjustment.  For a large firm, this might be a continual process, but for a smaller firms it might involve a regular review instead.

For users of the Aviva Development Zone, our Course of the Month for July is ‘Vulnerable Customers – Introduction’, which covers the FCA’s latest guidance. Why not take a look and check if your knowledge and understanding is up to date?

If you’re not signed up to the Development Zone, you can visit the website at for a free 14-day trial.

About the author

Lisa joined RWA in 2014 as an e-Learning Assistant and now heads up RWA’s Design and Content Team. Her role as Head of Content and Communications involves managing content creation and curation on the Aviva Development Zone platform and serving as editor of RWA Insight.

Lisa has diverse creative and technical writing experience. She holds a first class honours degree in English and Creative Writing from Swansea University and graduated from Cardiff Metropolitan University with a Distinction in Creative Writing in 2016.

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