The FCA has shared its findings on good and poor practice by payments firms in delivering good outcomes for consumers in vulnerable circumstances. The review assessed how firms identify vulnerability, provide support, communicate effectively and monitor outcomes under the Consumer Duty. The published findings offer practical examples that payments and e-money firms can use to strengthen their approach to treating vulnerable customers and meeting Consumer Duty expectations.
The FCA has made clear that these findings do not introduce new requirements or prescribe a particular way for firms to meet its expectations. Not every example will be relevant to every firm, and firms should consider what is appropriate based on their business model, customer base, products and services, and the nature and level of vulnerability within their target market.
Firms delivering the strongest outcomes had a clear understanding of the characteristics of vulnerability in their customer base, effectively identified and recorded vulnerability, provided appropriate and consistent support tailored to customer needs, defined and monitored customer outcomes, used management information and governance to drive improvements, and continuously reviewed and enhanced their approach over time. These firms focused on the vulnerability drivers most relevant to their customers while remaining flexible enough to support other needs.
By contrast, the FCA identified a number of poor practices and deficiencies in firms that had policies and training in place but could not demonstrate how they worked in practice; firms that identified very few (or no) customers in vulnerable circumstances despite customer bases where vulnerability would reasonably be expected; heavy reliance on individual staff judgement with limited supporting processes; inconsistent recording and sharing of vulnerability information across the customer journey; limited testing or assurance of policies; inconsistent application of support; limited tailoring of communications; weak management information and outcomes monitoring; and insufficient oversight of intermediaries.
Why This Matters for Payments Firms
- Identifying and Recording Vulnerability
Identified poor practices included reliance on staff judgement without consistent processes, limited testing of whether policies operated effectively, and very low numbers of identified vulnerable customers. Some firms could not consistently evidence how vulnerability information was recorded and shared across the customer journey.
Identified good practices included embedding identification across customer journeys (including online and automated channels), using system flags, training staff to recognise indicators such as limited English, hearing difficulties or low digital capability, and testing processes through call listening and quality assurance. Some firms actively prompted customers about support needs during applications or used technology to analyse language in chats and route customers to human agents.
- Supporting Consumers in Vulnerable Circumstances
Identified poor practices included limited evidence that support arrangements were achieving good outcomes, inconsistent application of support across the customer journey, and weak linkage between identified vulnerability and tailored actions.
Identified good practices included designing support around identified needs, offering flexibility in timing, channels and formats, and ensuring support was applied consistently. Practical examples included assisted onboarding and alternative channels for customers with limited IT skills, multi-lingual support for money remitters, and testing different support options before scaling. Smaller firms demonstrated proportionate approaches, such as offering call-back support for customers with limited digital literacy.
- Consumer Understanding and Communications
Identified poor practices included primary reliance on standard communications with limited tailoring, insufficient assessment of whether communications were understood in practice, and limited flexibility in how customers could engage.
Identified good practices included clear, accessible communications tailored to different needs, use of alternative formats and channels, and testing materials with vulnerable customers or advocacy groups. Examples included adapted communications for non-English speakers and multi-lingual support online or by phone.
- Governance, Management Information and Outcomes Monitoring
Identified poor practices included infrequent or limited MI provided to senior management and boards, weak monitoring of outcomes for vulnerable customers, reliance on individual examples rather than broader trend analysis, and limited structured approaches to continuous improvement.
Identified good practices included defining what good outcomes look like for different customer needs, collecting and analysing MI on vulnerability characteristics and outcomes, providing regular reporting to senior management and boards, and using insights from complaints, quality assurance and customer interactions to drive improvements.
- Overseeing Intermediaries
Identified poor practices included limited visibility of vulnerability among customers served by intermediaries and insufficient evidence of how outcomes were being monitored.
Identified good practices included monitoring complaints and outcomes for customers served via intermediaries, providing training to intermediary staff, collecting performance MI, and taking action where issues arose.
What Firms Should Consider
Firms should review their current arrangements against these findings and be able to demonstrate that they:
- Understand the scale and nature of vulnerability in their target market and customer base.
- Identify and record vulnerability consistently across all channels.
- Translate identified needs into practical, consistent support and reasonable adjustments.
- Communicate in ways that support understanding and informed decision-making.
- Monitor outcomes for vulnerable customers through meaningful MI and use the insights to improve.
- Apply proportionate but effective oversight of any intermediaries.
These considerations should be read alongside the Consumer Duty requirements in PRIN 2A and the FCA’s FG21/1 Guidance for firms on the fair treatment of vulnerable customers. The FCA’s objective is for consumers in vulnerable circumstances to experience outcomes as good as those experienced by other consumers.
How Complyport Can Help
Complyport supports payments firms, e-money institutions and other financial services firms in embedding the Consumer Duty and strengthening support for customers in vulnerable circumstances.
Our specialists can assist with:
- Review and assess your existing Consumer Duty framework;
- Carrying out Consumer Duty and Vulnerability Gap Analyses aligned to regulatory expectations;
- Enhancement of existing identification, recording and support processes across customer journeys;
- Development of proportionate Management Information and outcomes monitoring frameworks;
- Training for staff and senior management on Vulnerability, Treating Customers Fairly and Consumer Duty; and
- Oversight Frameworks for intermediary distribution models.
Book a Meeting with a Complyport SME
To discuss how the FCA’s findings and identified good and poor practices impact your business and how Complyport can help strengthen your approach to vulnerable customers under the Consumer Duty, contact us today to book a meeting with one of our Subject Matter Experts.
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