14/08/2026
The FCA's March 2025 vulnerable customer review found that less than half of firms had formal governance bodies overseeing outcomes for customers in vulnerable circumstances.
Only four in ten consumers with vulnerability characteristics had disclosed their circumstances to their financial services provider.
And firms were monitoring process outputs rather than actual customer outcomes.
These are not theoretical gaps. They are the specific areas the FCA will be assessing during its ongoing Consumer Duty supervisory work.
We have just published the Vulnerable Customer Policy & Procedures Playbook — a comprehensive framework for FCA-regulated firms that translates the FCA's expectations under FG21/1 and the Consumer Duty into practical, implementable policies and procedures.
It includes governance frameworks with SMCR accountability mapping, six identification methods with staff conversation prompts, a four-level escalation matrix, MI frameworks with specific metrics, product review and communications checklists, and nine ready-to-use appendix templates.
Designed for compliance officers, senior managers, MLROs, and anyone responsible for demonstrating that their firm delivers good outcomes for customers in vulnerable circumstances.
http://dlvr.it/TV1Gzy
