You’ve strengthened your policies. Trained your staff. Built escalation procedures. You know your firm is doing the right thing to support vulnerable customers.
But here’s the big question: Do they know that?
In the FCA’s latest vulnerability review, many customers said they didn’t feel supported, even when firms believed they were doing everything right.
This disconnect isn’t about neglect. It’s about communication, perception, and trust.
For compliance teams in regulated firms – especially in high-pressure sectors like motor finance, personal loans, insurance, and collections – this gap carries real risk. If vulnerable customers don’t experience the support you’ve designed for them, it undermines your intent and could leave you exposed under Consumer Duty.
Here’s why visibility matters just as much as policy and how you can close the perception gap in your firm.
The gap between policy and perception
The FCA’s 2024 vulnerability review highlights a recurring theme: firms often think they’re supporting vulnerable customers, but customers don’t feel supported.
Nearly 6 in 10 (58%) of vulnerable customers either do not know if there is anything in place or feel that they know nothing is in place to help overcome communication issues they may face
And yet, 70% of those who have experienced such issues say providers did offer suitable alternatives.
The problem isn’t provision. It’s awareness.
That lack of visibility could mean customers continue to rely on unsuitable channels, miss support options, or feel excluded from meaningful engagement, especially those in vulnerable circumstances.
Consumer Duty means seeing it from their side
Consumer Duty has changed the game. Firms must now focus on outcomes, not just intent. This means shifting the lens from policy to experience. One Head of Compliance recently put it simply:
“I always ask: would my elderly mum understand this?”
It’s a powerful test and one every Compliance team should apply. Because clarity, tone, and format matter as much as regulatory accuracy.
Instead of asking:
- Did we send the letter?
- Did we follow the script?
Ask:
- Would someone in distress feel confident responding?
- Would my own parent know what support is available—and how to access it?
That’s what true vulnerable customer support looks like. It’s not just compliant, it’s human.
Default channels don’t work for everyone
Firms still rely heavily on email and letters to communicate. According to the FCA:
- 68% of consumers received information via email
- 38% received it by letter
But these channels don’t work for everyone. Customers with mental health conditions, cognitive challenges, or low literacy may struggle to understand or engage with written formats.
Even worse, many don’t know they have a choice.
The FCA notes:
“A lack of awareness of alternatives could mean some consumers continue with letters and emails despite a more suitable alternative being available.”
So while alternative channels, like phone, live chat, or accessible formats, may exist, if they’re not proactively offered, they’re not truly available.
Frontline consistency is critical, but often missed
Even the best-designed support strategies rely on frontline delivery.
But in busy contact centres, it’s easy for agents to:
- Miss subtle signs of vulnerability
- Use confusing language
- Skip over available support options
- Assume customers already know their rights
Unless you’re listening to a high volume of interactions, you’ll miss these moments.
That’s why leading firms are investing in proactive QA and 100% interaction monitoring, to surface patterns, reduce inconsistency, and protect both customers and the business.
Make support visible, not just available
Here are five ways to help vulnerable customers see and feel the support you already provide:
✅ Signpost help clearly in conversations
Don’t assume customers will ask. Tell them what’s available.
✅ Review scripts, letters, and emails for clarity
Use plain language. Reduce cognitive load. Make actions clear.
✅ Offer communication alternatives proactively
Add a line to say: “If email isn’t the best way to contact you, let us know what works better.”
✅ Empower agents to support, not just escalate
Build confidence through training and reinforce with coaching.
✅ Monitor interactions at scale
Spot blind spots. Track how support is delivered. Learn what’s landing and what isn’t.
You’re doing more than you think, make sure it shows
You aren’t short on intent. You do have the right policies, training, and culture in place.
But good work behind the scenes doesn’t protect customers—or the business, unless it’s visible in every interaction.
That means:
- Making support obvious, not assumed
- Keeping it empathetic, not just procedural
- Ensuring it’s monitored and measured, not just mandated
When you focus on perception, not just provision, you build trust, reduce risk, and deliver on your duty.
Final thoughts: Make the invisible visible
As a Compliance leader, you carry the responsibility of protecting those who need it most.
But doing the right thing isn’t enough if customers don’t know, feel, or trust that help is there. That’s why now is the time to pause and ask:
Would my elderly mum understand this? Would she feel supported? Would she know what to do next?
If the answer isn’t a confident yes, there’s work to be done.
By making support more human, more visible, and more consistent, you won’t just meet regulatory expectations, you’ll live up to the values your customers deserve.
