The FCA’s Vulnerability Review: Our key takeaways

The Financial Conduct Authority (FCA) recently published its Vulnerability Review, highlighting how businesses across the sector are supporting customers in vulnerable circumstances. We attended their webinar, ‘The Vulnerability Review: Findings and Next Steps’, to explore key insights and what they mean for financial services, particularly from a digital accessibility and service design perspective.

Understanding and responding to vulnerability

The FCA’s review aimed to track:

• Actions firms have taken to understand and respond to customer vulnerability
• Outcomes experienced by vulnerable customers
• Stakeholders’ views on the FCA’s vulnerability guidance within the Consumer Duty framework

One of the clearest messages from the webinar was that vulnerability is not a static state— it often impacts individuals in diverse ways, from access needs to support through traumatic life events. Organisations should strive to be proactive in identifying and supporting customers in vulnerable situations rather than relying on people to self-advocate, and embedding inclusion at the core of their teams, products and services.

The impact of inaccessible services

A powerful perspective came from Ishmael, who has a learning disability, and spoke about his experiences navigating financial services. He described difficulties in making phone calls and processing large amounts of information and technical terminology at once, which can be overwhelming. One of the most critical aspects of his experience was the importance of feeling heard and not being rushed when accessing support.

Ishmael’s story also really highlighted the importance of financial organisations communicating in clear, jargon-free terms, ensuring materials are written in plain English with a focus on readability. Providing flexible service options allows customers to engage through their preferred channels, reducing barriers to access. Moreover, businesses should take a proactive approach to support, following up with vulnerable customers rather than expecting them to repeatedly chase resolutions on their own.

Embedding inclusion

Charlotte Clark, Director of Cross-Cutting Policy & Strategy at the FCA, noted that while progress has been made, there is still significant work to do in embedding vulnerability considerations at the heart of financial service design. Some firms are responding well to complex, individual needs, leading to greater trust and better customer relationships. However, others are still falling short, with rigid processes creating unnecessary barriers to access for their customers.

Some of the key areas for improvement

Tailored and accessible communications

Many firms are attempting to personalise customer interactions, yet vulnerable customers often find existing communication strategies insufficient.

Continuous user testing and iteration

Services should be continuously tested with real users with diverse abilities, and continue to iterate on this basis

Improved training for frontline teams

A major gap in progress has been a lack of training and awareness among customer-facing teams to understand and respond to vulnerability.

Data-driven insights

Organisations need to collect more granular data, both qualitative and quantitative on customer vulnerability, in order to design better support mechanisms and track outcomes more effectively.

During the panel session, speakers shared the following examples of organisations taking proactive approaches:

• A bank assigned a dedicated representative to check in on a vulnerable customer every three weeks, significantly improving trust and engagement
• Some firms are introducing easy-read materials, flexible customer service scripts, and alternative communication methods like video calls with sign language interpreters
• Certain home insurance providers now proactively call vulnerable customers before significant weather events, offering reassurance and assistance

However, many firms still struggle with rigid processes that fail to accommodate people’s access needs, such as requiring deaf customers to call in or asking individuals with mobility challenges to visit branches.

A more inclusive future

Howard Taylor from PwC emphasised that designing for accessibility benefits everyone, not just those who are currently classified as vulnerable. Nearly half the population may experience vulnerability at some point, so inclusive design should not be considered an edge case but a core principle of service development.

Organisations must embed vulnerability considerations from the outset rather than attempting to retrofit solutions later. By designing services with inclusivity in mind, they can ensure that all customers, regardless of their circumstances, have equitable access to financial products, advice and support.

Equally important is empowering staff to step outside rigid processes. Training customer-facing teams in empathetic, human-centred decision-making will enable them to better recognise and respond to customer vulnerability. When employees are given the tools and autonomy to provide personalised support, customers feel heard, valued and supported.

Another priority is improving the monitoring of customer outcomes. Many companies struggle to track how well their services meet the needs of vulnerable customers. By implementing more effective feedback mechanisms and data collection processes, organisations can iteratively refine their approach.

Finally, ensuring non-digital support options are clearly communicated is critical. Research shows that six in ten disabled customers are unaware of alternative assistance available when they encounter digital barriers. Firms must do more to promote and provide accessible alternatives, taking cues from organisations such as Citizens Advice, which implement this strategy well.

As the financial sector continues to adapt under the Consumer Duty framework, the challenge is not just compliance—it’s about meaningful change that prioritises customer needs. When firms get this right, it doesn’t just improve experiences for vulnerable customers; it builds trust, reduces complaints, and leads to better business outcomes overall.

How we can help

At Nexer Digital, we specialise in inclusive service design, helping organisations embed accessibility and vulnerability considerations into their digital products and services. If you’re looking to refine your approach, from accessibility audits and training for your team, to content design to user journey mapping, get in touch to learn how we can support you.