The FCA expects firms to actively consider vulnerability when designing and reviewing customer communications, rather than treating it as a separate compliance consideration. This includes recognising that many customers may have low financial confidence, literacy challenges or accessibility needs.
Good practice involves building vulnerability considerations into the design process from the outset. This may include using plain language, reducing complexity, and ensuring that key information is presented clearly and consistently across all channels.
Firms should also consider how customers can disclose additional needs and how those needs are recorded and acted upon. Simple process adjustments, such as prompts within systems or preference recording tools, can significantly improve customer experience and understanding.
Where firms identify that vulnerable customers are not receiving good outcomes, this should be investigated promptly. The focus should be on understanding the cause, taking appropriate action, and ensuring improvements are made to prevent recurrence.
