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Positive practices in supporting vulnerable customers
The review shows that some companies have made notable progress in supporting vulnerable customers and improving outcomes. For example, a few companies effectively use customer data to monitor outcomes and identify discrepancies. Some also provide tailored support, ensuring staff are well-trained to recognise and respond to vulnerable customers.
Improved communication is another strength for some – ensuring customers can make informed decisions. Additionally, certain companies are integrating consumer feedback into product and service design, ensuring that solutions better meet the needs of vulnerable customers.
Areas for improvement
However, the FCA's review found notable gaps in meeting Consumer Duty requirements. A major shortcoming is the ineffective monitoring of customer outcomes. Many companies struggle to define what good outcomes look like, lack clear measurement frameworks, and fail to act on identified issues.
Insufficient consumer support is another concern. Several companies don’t have effective systems to identify and assist vulnerable customers. In some cases, customers are hesitant to disclose vulnerabilities, and when they do, companies often fail to take appropriate action.
Training gaps are also evident – particularly in product design – with many companies lacking structured processes to integrate consumer needs into product development. Staff often receive minimal training on considering vulnerability, leading to products that don’t adequately serve all customers.
Governance and leadership also present challenges. While some companies demonstrate strong engagement from higher up, the FCA review found many lack effective governance processes to oversee consumer outcomes. In particular, smaller companies struggle to establish clear accountability structures, which impacts their ability to act on poor outcomes.
Strengthening governance and monitoring
Effective governance is crucial to ensuring good consumer outcomes. Companies with strong governance frameworks can clearly define what positive outcomes should look like, and use high-quality data to assess customer experience. For example, the FCA praise a mortgage intermediary who uses customer review data scores and comments to monitor customer outcomes.
However, many companies currently lack these frameworks, resulting in poor data collection and unclear action plans when negative outcomes emerge.
Improving consumer support
Providing proactive and effective customer support is essential under Consumer Duty. Good practices include training frontline staff to recognise signs of vulnerability, and offering flexible support based on individual needs. Companies that excel in this area make assistance easily accessible and adaptable.
However, many companies fell short by requiring customers to repeatedly disclose their circumstances, or by offering inflexible, standardised support. This often leads to frustration and poor customer experience.
Enhancing consumer communication
Clear communication is another key requirement. Leading companies communicate in plain language, provide information at appropriate times, and offer multiple engagement channels. Some also test their communication methods to ensure clarity and effectiveness.
However, many companies still struggle with inconsistent and unclear communication, especially for vulnerable customers.
Designing inclusive products and services
Product and service design must prioritise inclusivity. Successful companies incorporate customer feedback into development processes, engage with third parties like charities, and create product features to address specific needs.
However, many currently lack structured approaches to test products against the needs of vulnerable customers. Additionally, limited training for product development teams often results in solutions that don’t adequately serve all consumer groups.
Moving forward
While there are some encouraging signs, there’s still work to do across the industry. Companies that embrace best practices – such as using review data, adopting vulnerability assessments, and holding staff training – stand a better chance of effectively meeting the needs of vulnerable customers.
For more details, read the FCA’s full update here.
Smart Money People’s impartial review data can help your company to evidence outcomes for Consumer Duty.
Plus, our bespoke surveys allow you to gather sensitive feedback securely – without the results being published on our platform – perfect for gathering insights from specific groups like vulnerable customers.
To learn more, contact our Business Development team.
