We have reviewed how firms are supporting customers in vulnerable circumstances and whether our existing guidance is still appropriate.
We may all find ourselves in vulnerable circumstances at some time in our lives. These circumstances can affect what we need and how we engage with our financial services provider, and make us more susceptible to harm.
In this context, we want firms to act to deliver good outcomes for customers in vulnerable circumstances. We recognise this can be complex.
Last year, we evaluated firms’ actions in line with FG21/1: 'Guidance for firms on the fair treatment of vulnerable customers[2]' (the Guidance). We did so to:
- Test how firms are supporting customers in vulnerable circumstances.
- Consider whether our existing vulnerability guidance remains appropriate in light of the Consumer Duty[3].
We found many examples of positive actions by firms across sectors, as well as some areas for improvement.
We also saw a renewed focus among firms on delivering good outcomes for consumers in vulnerable circumstances because of the Consumer Duty.
However, we know from the Financial Lives survey[4] and new consumer research[5] which we specially commissioned that consumers in vulnerable circumstances continue to report poor outcomes when compared with other consumers.
Although our research showed that consumers were able to report good examples of firms responding flexibly to meet their needs and offer tailored support, consumers continue to report challenges, particularly if they have multiple characteristics of vulnerability.
Given the complexity and evolving nature of vulnerability, we want to work with firms to continue driving improvements in practice and outcomes.
We want consumers to receive good outcomes, consistent with the Consumer Duty.
As part of our review, we spoke to stakeholders including firms, trade associations, consumer organisations and academics. They were clear that the Guidance remains useful and important under the Consumer Duty. On this basis, we are not revising our Guidance now or introducing new requirements for firms.
Rather, stakeholders suggested more case studies would help support firms.
We have therefore published case study examples of good practice and areas for improvement[6].
Our approach
As part of our review, we gathered data to understand:
- Actions firms have taken to understand and respond to the needs of customers in vulnerable circumstances.
- The outcomes experienced by customers in vulnerable circumstances.
- Stakeholders’ views of the Guidance, including its continuing relevance under the Consumer Duty.
Interviews with experts on vulnerability and financial services
We interviewed stakeholders from consumer organisations, trade associations and academia to get different perspectives on:
- How firms have taken action to support customers in vulnerable circumstances.
- Consumer outcomes.
- The effectiveness of the Guidance.
Research into experiences of consumers in vulnerable circumstances
We commissioned quantitative and qualitative consumer research, including a survey of 1500 consumers.
Read the report[5]: Improving understanding of the outcomes for consumers in vulnerable circumstances when engaging with firms
Analysis of Financial Lives survey data
We explored a broad range of poor outcomes using established measures within the 2020, 2022 and 2024 Financial Lives[4] survey data.
Firm survey
We analysed responses from 725 firms to a voluntary multiple-choice survey to identify:
- Where firms have taken actions to implement the Guidance.
- Patterns across different sectors.
- Areas for possible further investigation.
Multi-firm work: outcomes monitoring
We sent a follow-up information request to 29 firms across 12 markets.
This request focused on how firms’ practices were affecting outcomes for customers in vulnerable circumstances, and how those outcomes were being monitored.
Multi-firm work: power of attorney and bereavement customer journeys in retail banking
We sent an information request to 7 banks and building societies about these processes, to better understand how firms manage power of attorney and bereavement customer journeys.
Our findings
Next steps
We encourage firms to make use of our examples of good practice and areas for improvement[9].
To drive further improvements, we'll continue to take account of outcomes for customers in vulnerable circumstances across our Consumer Duty work with industry.
We will also continue to engage with industry to support continuous improvement, particularly in areas that firms find more challenging when supporting customers in vulnerable circumstances.
We will not be updating our Guidance for firms on the fair treatment of vulnerable customers, as we have concluded that it remains appropriate and helpful alongside the Consumer Duty, based on feedback from this review.