Vulnerable Customers Policy

Having a defined and structured Vulnerable Customer Policy in place is not only a regulatory requirement under the FCA’s Consumer Duty, but also a key part of delivering good customer outcomes. This manual provides practical guidance to help firms identify and support customers with characteristics of vulnerability, ensuring they are treated in a fair, clear and consistent manner throughout their journey.

From 31 July 2023, Treating Customers Fairly (Principle 6) was replaced by the Consumer Duty (Principle 12), which explicitly highlights vulnerability as a core consideration. As a result, this manual was fully updated to reflect the Consumer Duty requirements, with a particular focus on helping staff and advisers recognise indicators of vulnerability and respond appropriately to individual customer needs.  We also introduced a dedicated section: Supporting Customers in Financial Difficulty. This section provides additional guidance on recognising when customers may be struggling financially and outlines how staff and advisers can offer appropriate support and explore available options to help customers navigate their circumstances.

We continue to review and enhance this manual in line with emerging guidance and best practice. Most recently, we updated the manual following the FCA’s Multi-Firm Review on the treatment of customers in vulnerable circumstances (published March 2025). This update includes practical advice on identifying where customers with characteristics of vulnerability may be receiving poor outcomes and steps to take to address these effectively.

The manual is designed to be both compliant and actionable, supporting your firm in embedding good customer outcomes across all regulated activity.

FORMAT: All documents are downloadable via email upon receipt of payment.

Written & reviewed by the Ecompli founder — With over 20 years in financial services and having founded Ecompli in 2006, our compliance documents are written by a specialist with hands-on expertise in FCA regulation across the mortgage, general insurance, equity release, and insurance claims handling sectors. Every guide and template is personally developed to turn complex regulatory requirements into clear, practical tools your firm can actually use.

There are plenty of free templates and AI-generated documents available online. The challenge is knowing whether they genuinely reflect FCA requirements, align with Consumer Duty expectations and work in practice for your firm. Our documents are written by Ecompli’s founder and are designed specifically for regulated firms. Every manual, register and template is created to provide practical, usable guidance that supports implementation,  helping firms move beyond theory and into demonstrable compliance.