Vulnerable Customer Policy & Procedures Playbook
A comprehensive, ready-to-implement framework for FCA-regulated firms. Aligned to FG21/1, the Consumer Duty, and the FCA’s March 2025 Vulnerable Customer Review findings.
- 30+ page Word document, fully editable
- Nine ready-to-use appendix templates
- SMCR accountability mapping
- Governance forum terms of reference
- Identification, escalation, and monitoring frameworks
- Product review and communications checklists
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The FCA’s March 2025 Review Found Significant Gaps
The regulator’s multi-firm review identified clear areas where firms are falling short of expectations. Can your firm answer these questions?
Governance Gaps
Less than half of firms had formal governance bodies overseeing vulnerable customer outcomes. Senior leadership engagement was often theoretical rather than genuine.
FCA March 2025 Review
Outcomes Not Defined
Firms could not clearly articulate what a “good outcome” looks like for vulnerable customers, making effective monitoring impossible.
FCA Good Practice Report, March 2025
Training Shortfalls
Only 54% of firms with vulnerability training for non-frontline staff provided guidance on how vulnerability relates to their specific roles.
FCA March 2025 Review
Product Design Blind Spots
Product and service design teams rarely received vulnerability training, creating a significant gap between customer needs and product delivery.
FCA Good Practice Report, March 2025
Low Customer Disclosure
Only four in ten consumers with vulnerability characteristics disclosed their circumstances. Approximately a quarter felt uncomfortable doing so.
FCA Consumer Research, March 2025
Poor MI Quality
Firms were monitoring process outputs rather than actual customer outcomes. Many underestimated the depth of monitoring required by the Consumer Duty.
FCA Good Practice Report, March 2025
What’s Inside Your Playbook
A structured, comprehensive framework covering every aspect of vulnerable customer management — from identification through to Board-level governance.
Document Control & Governance
Version control, SMCR accountability mapping, and Vulnerable Customer Governance Forum terms of reference.
Defining Vulnerability
FCA definition, spectrum of vulnerability, four drivers with practical characteristics and examples.
Identification Procedures
Six identification methods, staff conversation prompts, and empathetic questioning techniques.
Recording & Data Management
Vulnerability Record Template, UK GDPR considerations, and centralised recording standards.
Response & Escalation
Flexible support procedures, four-level escalation matrix, and power of attorney/bereavement processes.
Products & Communications
Inclusive product design framework, product review checklist, and communication accessibility standards.
Training & Competence
Staff training matrix by audience, content, frequency, and delivery method. Staff wellbeing provisions.
Monitoring & Outcomes
MI framework with metrics, outcomes monitoring checklist, and compliance monitoring programme.
Third-Party Management
Due diligence requirements, outsourcing standards, and third-party vulnerability monitoring.
Nine Appendix Templates
Ready-to-use templates including record forms, checklists, flowcharts, and governance terms of reference.
Built For Your Role
Whether you’re responsible for policy, governance, or frontline delivery, this Playbook equips your team.
Compliance Officers
Ready-to-implement policy framework with monitoring checklists and compliance programme guidance.
Senior Managers (SMCR)
Clear accountability mapping, governance forum structure, and Board reporting framework.
MLROs
Vulnerability considerations integrated with financial crime reporting and safeguarding procedures.
Risk Professionals
MI framework, outcomes monitoring metrics, and escalation thresholds for risk assessment.
Product Teams
Inclusive design principles, product review checklist, and target market vulnerability assessment.
Operations Leaders
Staff training matrix, escalation procedures, and customer journey improvement framework.
Aligned to Key Regulatory Frameworks
Every section of this Playbook maps directly to the regulatory requirements your firm must meet.
Ready to Strengthen Your Vulnerable Customer Framework?
Stop relying on ad-hoc approaches. Implement a structured, FCA-aligned framework that protects your customers and demonstrates compliance.
