Vulnerable customers considerations

The Consumer Duty as a whole emphasises the importance of suitability and appropriateness of products and services to their target markets, as well as consumer outcomes. This builds on existing guidance on fair treatment of vulnerable customers (FG21/1).

The Duty makes explicit reference to firms paying attention to the needs of customers with characteristics of vulnerability, who have additional needs or be at greater risk of harm.

It establishes an expectation that firms proactively identify the outcomes and establish appropriate practices for different groups of customers, in particular vulnerable customers, including as part of target market analysis. This expands product lifecycle requirements that are already familiar in some sectors e.g. consumer credit, across all in-scope firms and products and sets clear culture and governance expectations.

The balance of expectations where duties to ensure products and services have fair value, are transparently sold and properly marketed, underlines the importance of providing sufficient information to inform consumer decision making. This identifies a clear balance of responsibility weighted towards the firm where target customers can be expected to have characteristics of vulnerability.

Practically speaking, this cuts across all aspects of product design, sales and management. Guidance highlights the importance of testing communications and customer services methods, particularly taking into account customer vulnerabilities. Firms are expected to be proactive in monitoring outcomes for vulnerable customers and using data collected to drive improvement, too.