The FCA’s Consumer Duty places vulnerable customers at the heart of regulation. Firms are expected not only to identify and support vulnerability but to evidence that customers in vulnerable circumstances consistently achieve good outcomes.
In its recent supervisory work, the FCA has shared examples of good practice, including the use of artificial intelligence (AI) to help identify potential characteristics of vulnerability.
For compliance, QA, and operations leaders, the challenge has two parts: ensuring frontline processes deliver in practice, and proving to the FCA that they do.
Why vulnerable customers are a priority
- Nearly 50% of UK adults display one or more characteristics of vulnerability (FCA Financial Lives Survey 2022).
- Under Consumer Duty, firms must monitor and test whether good outcomes are being achieved.
- The FCA has stressed that evidence is as important as delivery. Firms must be able to show how outcomes are tracked, measured, and improved.
This is not a niche issue. It is a day-to-day operational reality for every regulated firm.
Consumer Duty and vulnerable customers: The FCA’s expectation
The Consumer Duty makes clear that all customers should receive good outcomes. For those in vulnerable circumstances, firms are expected to:
- Define what good outcomes look like for their products and services.
- Put in place systems to monitor and evidence those outcomes.
- Adapt processes and policies to address risks and prevent recurrence.
- Ensure governance and senior leaders are accountable for delivery.
In practice, this means firms need to go beyond written policies and embed vulnerability management across frontline teams, systems, and governance structures.
Common vulnerability gaps in compliance monitoring
Even firms with strong compliance cultures can face challenges:
- Limited sampling: Reviewing only 2–5% of calls leaves most interactions unchecked.
- Subjective judgement: Vulnerability cues are often subtle, leading to inconsistent outcomes.
- Delayed action: Signs may not be identified until it is too late to intervene.
- Evidence shortfalls: Difficulty proving to the FCA how vulnerable customers fare compared with others.
These gaps risk poor outcomes for customers and increase regulatory exposure.
What FCA best practice looks like
From its guidance, the FCA expects firms to:
- Define good outcomes clearly for vulnerable customers.
- Equip and support frontline staff with skills, clear escalation processes, and wellbeing measures.
- Centralise data and disclosures so customers do not have to repeat sensitive information.
- Tailor support and communications to customer needs, using plain English and multiple channels.
- Test communications and outcomes regularly to ensure they remain effective.
- Engage senior leadership in active oversight and accountability.
Oversee outsourcing arrangements to ensure third parties treat vulnerable customers fairly, with clear due diligence and monitoring in place.
FCA best practice summary
The role of technology in meeting FCA expectations
The FCA has identified AI as a tool that can support good practice. Technology can:
- Monitor 100% of calls and digital interactions.
- Detect linguistic, tonal, and contextual cues beyond obvious keywords.
- Provide a consistent, auditable trail of vulnerability identification and support.
- Free compliance teams to focus on coaching, intervention, and outcomes rather than manual reviews.
This does not replace human judgement. Instead, AI augments staff capability, helping them identify risks earlier and act more effectively.
👉 Read more: AI Readiness in Regulated Firms
Why it matters
This is about more than compliance. Customers in vulnerable circumstances face higher risks if their needs are overlooked. Firms that get this right:
- Reduce compliance risk.
- Build customer trust and loyalty.
- Support staff with clear processes and escalation routes.
- Deliver better outcomes for their most at-risk customers.
Putting best practice into action
Every firm is at a different stage of maturity. Some are refining governance and MI, while others are exploring how technology can close gaps in detection and evidence.
The FCA’s guidance sets a clear benchmark. To help firms measure themselves against it, Voyc has created a Best Practice Checklist that translates regulatory expectations into 33 actionable questions across governance, staff capability, consumer support, and more.
👉 [Access the FCA Vulnerable Customers Best Practice Checklist here]
Frequently Asked Questions
What is FCA best practice for vulnerable customers?
The FCA expects firms to define good outcomes, monitor them, equip staff to act effectively, and evidence fair treatment for vulnerable customers.
How does Consumer Duty apply to vulnerable customers?
Under PRIN 2A.8, firms must monitor and evidence that vulnerable customers are not disadvantaged and achieve good outcomes comparable to others.
Can AI help meet FCA expectations on vulnerability?
Yes. AI supports best practice by monitoring 100% of calls, detecting subtle cues, and providing a defensible audit trail, while leaving final decisions to human reviewers.
Conclusion
The FCA’s message is clear: vulnerability is everyone’s responsibility. Firms that align with best practice not only meet regulatory expectations but also deliver better conversations, stronger trust, and fairer outcomes.
The first step is clarity. Do you know how your processes measure up?
