What does the FCA Vulnerable Customer Review Say: An Overview?

As you know, the FCA released their review ‘Delivering good outcomes for customers in vulnerable circumstances – good practice and areas for improvement’ at the start of March 2025.

An Overview of the FCA Vulnerable Customer Review

The review focused on the effective use of data to monitor customer outcomes, homing in on the need to segment target market analysis by vulnerabilities so firms can understand the outcomes that different groups of vulnerable customers receive. Remember - to form outcomes monitoring under the duty you need to identify what ‘good’ looks like, then work back to the data which tells you whether you’re providing the good outcome. What good looks like will be different for customers with different vulnerabilities. For some it may include understanding the basic concepts of the product, whereas for others it might include product flexibility.

Just a couple of examples there, but that leads onto the second part of this review: the need to offer a range of support solutions for customers. The FCA found that many firms either didn’t offer a wide enough range of solutions or their front-line teams were not aware of, or able to implement, them - indicating a real training need.

Linked to this is the need to tailor communications to the needs of vulnerable customers. As part of the product design or review, firms should fully understand their customer base and their needs then design communications to meet those needs. So, if you’re targeting customers with less experience with financial products, they may need more detailed information about how and when to use product features, make payments, etc. The same applies for vulnerable customers where their characteristics of vulnerability make it more difficult for them to understand the product or use all of its features, timely communication can be key.

Finally, the FCA highlighted concerns about the lack of tailored training. Firms should be creating training that:

• Highlights the types of vulnerabilities which may present in the customer base

• How those vulnerabilities can impact customers

• Solutions or interventions that can help customers manage those impacts – this is particularly important for staff who design products and services, not only front-line staff

• How to record the information, in accordance with UK GDPR, to ensure customers receive appropriate support and so the firm can use the data to design its customer support.

As the co-author of guidance on this subject for the Money Advice Trust I’m ideally placed to assist firms to implement those training requirements. As such we’ve ensured that our vulnerable customer e-learning is up to date with the Regulator’s feedback – this is perfect for a quick roll out to your team to cover off the areas highlighted. If you’re interested in a free trial of our e-learning simply email me: robert.bell@rbcompliance.co.uk