4 key drivers of customer vulnerability

What is a vulnerable customer?

According to FCA, a vulnerable customer is “someone who, due to their personal circumstances, is especially susceptible to harm – particularly when a firm is not acting with appropriate levels of care”.


The FCA’s guidance includes 4 key drivers of customer vulnerability:



Conditions or illnesses that affect one’s ability to complete day-to-day tasks, both mentally and physically.

These can be illnesses affecting hearing or a visual impairment. They are easier to spot in a conversation when a customer says “I can’t hear well” or “I cannot read the fine print”. Other conditions are more difficult to identify, such as mental health issues, cognitive disability or addiction.
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Life Events

Such as bereavement, job loss or relationship breakdown. 

This driver includes various circumstances that may negatively affect a person’s life, including but not limited to leaving care, seeking asylum, or getting a conviction.
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Low ability to withstand and manage financial or emotional shocks.

Vulnerable customers in this group often have inadequate or erratic income, low savings and often find themselves in debt.
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Limited knowledge of financial matters, lack of technological savviness or poor ability in areas such as digital communications and language skills.

These characteristics, for instance, can be found in foreigners whose English language skills might not be strong enough to understand complex conversations about finances. Additionally, some people find it difficult to operate digital portals, apps and other digital tools and struggle to learn new technology.
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FCA’s guidance

Vulnerable customers policy

Each firm should define specific characteristics of a vulnerability that appear more commonly within their customer base and target market. For instance, financial advisory firms that work with pensions and investments may come across customers with vulnerabilities involving health or life events associated with old age.  

Some characteristics of vulnerability are common across various customer segments and age groups. They can appear at any moment of time and overlap with or cause other vulnerability drivers. An example can be life events related to a loss of a partner, or interruption of the regular income. They can be coupled with digital illiteracy and lead to mental health issues like depression.

Voyc white paper

Download the Voyc white paper on vulnerable customers

Download the Voyc white paper on vulnerable customers