Vulnerability Support Checker
Proportionate controls and adjustments for customers in vulnerable circumstances
Why This Tool Exists
The FCA's Financial Lives Survey found that 47% of UK adults show characteristics of vulnerability. Under the Consumer Duty, firms must demonstrate they are delivering good outcomes for vulnerable customers — not just identifying them. Most firms have vulnerability policies that exist on paper but fail in practice: frontline staff lack training, identification is ad hoc, and there is no MI to show outcomes are actually improving. This tool provides a structured vulnerability assessment framework.
Who This Tool Is For
Frontline staff
Using a structured framework to identify and record customer vulnerability indicators
Compliance officers
Assessing the firm's vulnerability framework against FG21/1 and Consumer Duty requirements
Training managers
Identifying gaps in staff vulnerability awareness and building targeted training programmes
Board members
Understanding vulnerability MI and evidence requirements for board reporting
How to Use This Tool
Assess against the four drivers
Evaluate your framework against the FCA's four vulnerability drivers: health, life events, resilience, and capability.
Check your processes
Review how your firm identifies, records, acts on, and monitors vulnerability across the customer journey.
Review gaps and actions
Receive prioritised recommendations covering policy, training, systems, MI, and board reporting requirements.
Common Mistakes This Tool Prevents
Treating vulnerability as a binary flag rather than a spectrum that changes over time
How this tool helps: Uses the FCA's four-driver model to assess vulnerability as a nuanced, dynamic characteristic
Relying on customers to self-identify as vulnerable
How this tool helps: Provides proactive identification frameworks that don't depend on customer disclosure
Identifying vulnerability but not adjusting the service or product accordingly
How this tool helps: Links identification to specific actions and adjustments required for each vulnerability type
Not tracking outcomes for vulnerable customers separately from the general population
How this tool helps: Generates MI requirements specifically for vulnerable customer outcome monitoring
Related Guidance
Need Vulnerability Framework Support?
We can design your vulnerability policy, train frontline staff, implement recording systems, build MI dashboards, and prepare board-level vulnerability reporting — all aligned with FG21/1 and the Consumer Duty.
About the Vulnerability Support Checker
The FCA estimates that 50% of UK adults have characteristics of vulnerability. Under the Consumer Duty, firms must take reasonable steps to identify and support vulnerable customers to achieve good outcomes.
The FCA defines four key drivers of vulnerability:
- Health: Physical or mental health conditions, severe or terminal illness
- Life Events: Bereavement, job loss, relationship breakdown, caring responsibilities
- Resilience: Low income, over-indebtedness, low or no savings
- Capability: Low literacy/numeracy, poor financial knowledge, learning difficulties
These drivers can intersect and change over time. This tool helps you identify appropriate adjustments and support mechanisms at different stages of the customer journey.
Key Principles for Supporting Vulnerable Customers
- • Identify: Proactively ask and record (with consent) vulnerability indicators
- • Respond: Make reasonable adjustments to communication, processes, and decisions
- • Monitor: Track outcomes by vulnerability segment to ensure fair treatment
- • Train: Equip staff to recognize and respond appropriately to vulnerability
- • Govern: Report vulnerability MI to board and take action on poor outcomes
Need Vulnerability Framework Implementation?
We can help you design and implement comprehensive vulnerability frameworks, train staff, and build MI reporting aligned with FCA expectations.
Book Free Consultation →