Assessing your Vulnerable Customer Framework

Overview:

Protecting the interests of consumers in vulnerable circumstances is a key focus for FCA and a sector specific priority for Wealth Firms particularly.

Addressing consumer harms and protecting consumers is an area of increasing scrutiny from the FCA, with findings from the FCA multi-firm review of the treatment of customers in vulnerable circumstances due imminently (Q1 2025). Firms are expected to proactively identify and support vulnerable customers, and it is becoming increasingly important for firms to demonstrate how they are “acting to understand and respond to the needs of customers in vulnerable circumstances”⁽¹⁾ (FCA).

The treatment of vulnerable customers should be a core component of a firm’s strategy across the product lifecycle and should be integral to a firm’s strategy, product governance approach, culture and wider firm governance processes.

In this document we set out 3 key focus areas that firms can use an initial starting point when assessing whether their current vulnerable customer frameworks are sufficient in delivering good outcomes for all customers, based on our in-depth industry knowledge and wider market insights.

We also introduce our ‘Vulnerable Customer Maturity Matrix’, our newly developed toolkit to support you and your firm in your review and assessment of your vulnerable customer framework. Should you have any questions or wish to further explore the Maturity Matrix, please do not hesitate to contact our team

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References

¹ Source: Review of firms' treatment of customers in vulnerable circumstances | FCA