A Happy New Year? Supporting Customer Vulnerability


Simon Cavell

Simon Cavell

Consulting Senior Manager


The month of January brings fresh hope for the year ahead – resolutions made, dry January, booking a summer holiday. However, for many, the hangover from Christmas will include credit card bills, higher borrowing costs, and continuing Cost of Living pressure.

A Happy New Year?

During 2024, 900,000 people will see their mortgage bill increase by over £500. Energy bills have already increased by £700 per year. Nearly 7.3m households are sacrificing medicine, clothing, a shower, or meals.

The FCA’s own research suggests 1 in 2 UK consumers are vulnerable at any time, and we will all experience vulnerability during our life.

These sobering statistics are compounded further by a shortfall in understanding. Approximately 1 in 2 adults have the numeracy skills of a primary school child, 7.1m adults have a reading age of 9 years old, and 2.4m can not read at all. Many consumers simply can’t grasp the implications of their finances or where to go for help.

So how should financial services providers ensure they are addressing these challenges?

Identifying Vulnerability

Perhaps the largest task is identifying vulnerability in the first place. 

Over the past decade, we have seen a material shift from self-disclosure of conditions (frequently health-related). Self-disclosure certainly remains valid, but this is only part of the picture. Many customers are unwilling or unable to identify themselves as vulnerable. And vulnerability itself is more of a sliding scale than a binary status.

Today, the best firms are bringing together the rich customer data they hold to infer and identify signs of vulnerability – a sudden change in spending, regular healthcare payments, an emerging habit (such as gambling). With access to current account transactional data in particular, this insight can be invaluable and should be utilised.

Supporting Vulnerable Customers

It’s no surprise that vulnerability is woven through every aspect of Consumer Duty. Without identifying and understanding a customer’s position, is it really possible to act in their best interests? Stepping away from a ‘one size fits all’ approach enables us to ensure that products and services work for every customer, not just the majority.

There are five key areas to explore:

  1. Walking in the customers’ shoes - How far do you understand and empathise with their needs? If you don’t have direct understanding within your firm, how can you bring ‘lived experience’ into the organisation?  This again demonstrates the benefit of having a workforce as diverse as your customer base.

  2. Support by design - Are your products and services built with vulnerability in mind? Rather than assuming you know the impact, can you involve vulnerable customers in the design process and harness their ‘lived experience’?

  3. Being proactive - As well as reacting to self-disclosure, how proactively do you consider where and when customers need support? How can you anticipate, intervene, and adjust to ensure good outcomes for all? And how are your customer service colleagues trained to identify these signs and manage conversations?

  4. Communications for all - Rather than industry jargon, are your communications simple and easy to understand? Do they prompt all readers to take action? Are alternative formats and support available? Does your website enable plug-ins that support vulnerabilities (such as colour-blindness, dyslexia etc)?

  5. Offering additional support - Do you offer help and resources, either from your own trained colleagues or by introducing customers to skilled specialist partner organisations?

Want to learn more? We can help. 

Johnston Carmichael has supported a diverse range of financial services organisations with their implementation of Consumer Duty. Our work has included project implementation, complex change delivery, strategy development, change governance, assurance, learning, and Board/Exco engagement. We also enjoy our close, ongoing links with a range of industry experts, trade associations, and regulatory bodies.

Get in touch

Please get in touch with Simon or our wider team if you would like to explore how our support could be tailored to your requirements and budget.


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