Customers in vulnerable circumstances

Vulnerability may arise from a range of circumstances, including:

Your application should explain how staff will recognise these indicators and what action they are expected to take.

The FCA does not prescribe a single approach, but firms should explain how support is tailored to individual needs.

Examples may include:

If you have a dedicated Vulnerable Customer Policy, this should be referenced and submitted as supporting documentation.

Assuming vulnerability only relates to health conditions.
Having a policy but no practical process for identifying vulnerable customers.
Not explaining what support is available.
Treating vulnerability as a one-off event rather than something that can develop at any stage of the customer journey.