The objective

Protecting vulnerable customers and treating them fairly are key to Consumer Duty. Under the duty, you should make every effort to tune into, understand, and be sensitive to your customers’ experiences and feelings. While your experiences may not mirror those of your customers, it’s likely you’ve been in a vulnerable position before, too. Remembering that experience can help you approach a customer in a more empathetic way.

Who are vulnerable customers?

FCA defines a vulnerable customer as someone who is especially susceptible to harm due to their personal circumstances – particularly when a firm isn’t acting with appropriate levels of care.

The 4 key drivers of vulnerability include

Health conditions or illnesses affecting the person’s ability to carry out daily tasks


Major life events such as bereavement or relationship breakdowns


Low ability to withstand financial or emotional shocks



Low knowledge of financial matters, low confidence in managing money, or insufficient digital skills

Why is it important to understand vulnerable customers?

Research from the FCA in October 2020 shows 53% of adults identify themselves with multiple characteristics of vulnerability, which is 3 million more than in February 2020. If you don’t meet the needs of these customers, it could limit their ability to make decisions or represent their own interests and, as a result, put them at greater risk of harm.

Source: FCA, Guidance for firms on the fair treatment of vulnerable customers, October 2023.

How can you recognise vulnerable customers?

Identifying and addressing customer vulnerability from regulatory and social perspectives has been gaining momentum for the last decade. However, it can still be a difficult area to have customers talk about vulnerability as they may feel awkward and uncomfortable.

Here are some suggestions to approach them and deal with different types of vulnerabilities

  1. Ask them tactfully about potential support they might need without mentioning ‘vulnerable’. Here are 3 approaches widely used by psychologists and counsellors when dealing with vulnerable customers. They’re presented in acronyms: BRUCE, TEXAS, and IDEA.

BRUCEwhen the customer has a mental capacity limitation or English isn’t their first language


“Consider the things the customer says or does as these may suggest they’re struggling with decision-making”


“Would it be helpful if I put that in writing?”
“Is there someone that usually helps you with your finances?”


“Do you want to tell me what you’ve understood so far and I can fill in the gaps?”
“Would it help if I explained that again?”


“Is there another way you’d like us to communicate with you?”
“Is there another time when it would be better to have this conversation?”

(weighing up options)

“Would it be helpful to go through each option again?”
“Do you have someone you normally talk these things through with?”

TEXAS to gain consent to record sensitive information shared by the customer

Thank them

“Thank you for sharing.”
“I appreciate you telling me what’s going on for you.”

Explain how the information will be used

“This will mean you won’t need to keep repeating yourself.”
“It will help us support you better.”
“We can see what we can do to help.”

“This information will only be shared within our organisation.”

Gain eXplicit consent

“Are you happy for me to make a note of what you’ve shared today?”


“Is there anything you’d like us to do which will help?”
“Are you getting any help from anywhere – for example, family?”


“Some of our customers have found it helpful to speak to…”

“Leave it with me and I’ll see what more we can do to support you.”

IDEA when talking to a customer about their health or situation


“What are you finding hard?”
“What has been the impact on your day-to-day living?”


“When did this first start to happen?”
“How long have you been experiencing this?”


“Is this happening often?”
“Have you experienced this before?”
“Could it happen again?”


“Are you receiving any support/assistance/medication?”
“Have you asked about whether you’re entitled to more support/assistance/benefits?”

2. Look for subtle traits the customer may be showing, such as:

  • Being unexpectedly and highly emotional, erratic, farfetched or extreme
  • Struggling to understand information
  • Repeating themselves
  • Providing conflicting answers
  • Not recalling their basic information or recent conversations
  • Mentioning they’re moving into care or in with family

3. Understand internal and external information to evaluate their vulnerabilities, such as lapsed or late payments and increasing/decreasing contacts with the advisers.

How can you support vulnerable customers?

Understand the needs of your customers

Think about the variety of vulnerabilities that might exist in your client base and the impact those vulnerabilities might have when you’re making your recommendations and providing ongoing support. The support a customer may need will be very individual to them and by asking questions you’ll be able to establish what support they may need. For example, someone who is losing their sight may need help by explaining how to increase the font size of documents, all the way through to needing documents in braille.

Make sure you have the right skills and capability to recognise and respond to their needs

  • Attend training sessions to spot and respond to vulnerabilities quickly and effectively. Not only understand the theory of helping vulnerable customers, training your soft skills is where you bring your ‘A’ game.
  • Listen carefully to what the customer tells you. Sometimes, when people are telling us something, we’re often thinking about the best way to respond. With your customers, especially those who are vulnerable, it’s really important to take in what they tell you, their tone, and body language.
  • Avoid judgement. Your customers will be sharing personal information with you, as their adviser, from their finances to their health and family situations. It’s vital that you keep a neutral but inquisitive frame of mind when they disclose this kind of information to you and use it effectively to support them in their financial goals.
  • Show your empathy. Empathy is the ability to sense other people’s emotions, coupled with the ability to imagine what someone else might be thinking or feeling. When you’re being empathic, you’re focusing on the other person from their own perspective rather than yours. You’ll then be more sensitive to their experiences and feelings, which can reduce judgement and increase your compassion. It’ll help you pick up their vulnerability more quickly.

Tailor your communications 

  • Ask about their communication preferences (e.g. email and phone).
  • Offer a choice of communication channels to best fit the needs of those with health conditions and those without internet access. See the accessibility section of our website ( for more detail.
  • Avoid jargon and long written communications to make sure they fully understand the products and services.
  • Record the conversations. This way your customers can listen again to the potentially complicated product information you’re giving them and that will help them make the right decision for them.

Monitor and regularly assess whether you’re meeting and responding to their needs and make improvements when necessary

If you identify a vulnerable characteristic as defined by the FCA, it may mean categorising the person a vulnerable customer, please let us know by emailing us at or give us a call on 0808 133 1821, so we can provide enhanced support they might need and update our records accordingly.

We now want to continue our work with advisers to ensure Guardian and the firms who recommend us, can meet the duty in both letter and spirit to the benefit of our mutual customers, and we want to support advisers with what they need from us.

Phil Deacon
Head of Claims

Tools and Literature