2025 research: Vulnerability disclosure in the UK Mortgage market

This builds on our 2024 research, carried out in partnership with Newcastle Building Society, which provided the industry’s first comprehensive view into brokers’ understanding of vulnerability and the challenges of identifying it throughout the mortgage application process. That work led to the creation of a cross-industry “route of disclosure” guide.

This year, we’ve gone further by bringing lenders into the conversation. The new survey explores how well internal mortgage teams are set up to handle disclosures, giving us a fuller, sector-wide picture of how vulnerable customers are supported.

The report is designed to help brokers benchmark their approach and understand best practices, while giving lenders the insight to strengthen processes and improve collaboration. It also helps the wider industry see where progress has been made, and crucially, where gaps still remain.

Why this matters

Vulnerability can affect any customer at any time. In 2024, our research found that 89% of brokers reported encountering vulnerable clients, but more than 40% said they never passed this information on to a lender. At the time, many cited worries about how disclosure might affect mortgage applications, or unclear processes for doing so.

Fast forward 12 months, and our latest research shows progress, but also a notable gap between brokers and lenders. Brokers are identifying vulnerability more consistently and say they’re disclosing more often. Yet many lenders report they still rarely receive disclosures, suggesting vital information is still being missed.

Key findings

The full report is well worth a closer look, but here are a few standout findings:

• Brokers are spotting vulnerability:
• 87% of brokers reported encountering at least some vulnerable customers in the past year, with most estimating this affects between 1–10% of their client base
• Encouragingly, 52.3% now say they disclose more than half or all cases, compared with 2024 when more than 40% admitted they disclosed none.
• However, almost a third (30.9%) continue not to disclose any vulnerabilities to lenders.
• Disclosures aren’t always reaching lenders
• Over half of lenders (52.5%) said they had not received a single disclosure from a broker in the past 12 months.
• While some disclosures may be noted informally, the size of this gap suggests that many vulnerable customers are still being missed.
• Confidence is high but awareness varies
• Brokers scored an average of 9/10 in understanding the drivers of vulnerability, while lenders rated 8.3/10 for defining vulnerability and 8/10 for handling disclosures.
• However, only 61.8% of lenders agreed that the FCA’s vulnerability drivers cover everything they need, and one third admitted uncertainty.

• Barriers differ by perspective

• For brokers, the top barriers remain process-related. 44.3% say some lenders offer no clear route for disclosure, and 42.4% find it unclear how to disclose.
• For lenders, the main issues are seen as client-related. 77.9% believe customers don’t feel comfortable disclosing, and 63% think fear of application impact is a factor.
• Support and resources is key
• Brokers want clearer guidance (61.6%), step-by-step guides (49.5%), and better integration into systems (44.4%).
• Lenders prioritise dedicated online areas (56.3%), expert input (49.8%), and role-specific training.

Jess Trueman, Head of Business Development, Smart Money People, said:

“This year’s research shows a market moving in the right direction but still held back by structural and cultural barriers that prevent consistent vulnerability disclosure.

Brokers are confident in their understanding of vulnerability and most encounter it regularly in their client base. Encouragingly, more brokers now say they disclose “most” or “all” cases to lenders compared with 2024. But almost a third still disclose none – a reminder that awareness does not always translate into action.

Lenders report high confidence in their ability to act on disclosures but admit they receive them only rarely. More than half said they had not received a single disclosure in the past year, a stark contrast to brokers’ claims of increasing disclosure. This disconnect exposes weaknesses in the routes, systems, and consistency of communication between intermediaries and lenders.

The overall conclusion is clear: the knowledge is there, the willingness is there, but the infrastructure to support consistent disclosure is still not fit for purpose.”

Read the report