Making sense of the vulnerability

The FCA has published finalised guidance on the fair treatment of customers in vulnerable circumstances.

Soon enough, you'll need to show what you've done and whether it has improved customer outcomes. But there’s no simple formula or algorithm for meeting the challenge.

Here’s where our user-centric tools can help.

It's not always who you think

Customers in vulnerable situations are not edge cases. The FCA’s 2020 Financial Lives survey suggests that 46% of UK adults (24 million people) have one or more characteristics of vulnerability.

And no business is exempt from the challenge. In our research, we’ve seen affluent and educated people make flawed or erratic decisions when faced with new situations.

All it can take is a bereavement, a redundancy, a relationship ending. Life is full of twists and turns.

Someone who, due to their personal circumstances, is especially susceptible to detriment, particularly when a firm is not acting with appropriate levels of care.


The multiplier : COVID-19

Data from debt charity StepChange shows that thousands of people are being pushed into vulnerable situations as the effects of the pandemic play out.

2.5 million People facing financial crisis

5.6 million People struggling to afford essentials


5% of UK adults affected

Life events

29% of UK adults affected


27% of UK adults affected


20% of UK adults affected

It's a complex puzzle

The FCA's guidelines don't tell you exactly what to do. How could they? It regulates 60,000 firms – and says it's down to each one to respond appropriately.

The list of vulnerability drivers and characteristics they've created can help you think about the risks and harms that seem most relevant to your customer base.

But how will you successfully improve outcomes? The drivers are fluid and intersect unpredictably. And human lives rarely map neatly to even the most carefully categorised labels – we're reminded of that every day in user research.

This all makes providing an 'appropriate level of care' a complex problem. It’s no surprise that the firms we’ve spoken with are wrestling with similar questions.

What indicators of vulnerability are we looking for?

How do we identify customers in vulnerable circumstances?

How do we start the conversations with customers?

The right tools for the job

Fortunately, the tools we’ve been honing over the past fifteen years can help.

To understand

There’s one thing the FCA is crystal clear about: to achieve good outcomes every firm needs to understand its own customers like never before.

Qualitative research will take you beyond the myth of the average customer, to understand the breadth of needs of your target market and answer the question: what's an appropriate response for your business?

To respond

The most reliable way to ensure that all customers are treated fairly is to follow a user-centred design process that puts them at its centre. It will help you to:

  • Embed consideration of customer vulnerability across your business – from product and service design through to front-line delivery
  • Assess service effectiveness and reveal how to improve it
  • Build empathy and a healthier customer-centred culture

Our research draws on lived experience

We've designed services for cancer patients, people suffering financial shocks, survivors of domestic abuse, and people who have experienced a mental health crisis.

The key to success? Designing with them, not for them. It takes expertise and care to research with people in vulnerable situations, but it's worthwhile.

When Samaritans asked cxpartners to help design their first-ever chat service it was clear that the level of trust would need to be exceptional. But trust is easy to get wrong and indeed when we tested our working Samaritans prototype before it launched, it revealed a hidden problem.

Without a user-centred approach, an intervention intended to support service users may have instead increased risk of harm.

Samaritans Public Health England Talk to Frank Womens Aid
AXA Health National Health Service Bristol City Council RM Partners

Let's make your services better for everyone

If you're thinking about customer vulnerability as an obligation or purely in terms of risk reduction then you may be missing an opportunity.

Respond with a user-centred approach, and regulatory-driven changes can improve business health in other ways too.

Photo of Thomas Foster
"Through an exemplary focus on regulatory compliance and customer outcomes, cxpartners helped us achieve improvements in commercial performance."Thomas Foster
Director of Acquisitions, RAC

That's because when you design for people with a wide variety of needs, you gain insights into everyday problems. And you’re forced to come up with more robust solutions.

The result is innovation that benefits all of your customers.

Get started:

See the world through your customers' eyes

User research is a simple thing that you can do to understand the size of the gap, build impetus and alignment.

It’s been eye-opening to acknowledge how difficult we sometimes make things for our customers. Seeing that in one place creates a sense of urgency.


Our series on vulnerability


50 ways to carry out more inclusive user research

What can you do to ensure your research activity is inclusive? We’ve come up with 50 easy ways that you and your organisation can take on board when conducting more inclusive research in the future.



Don't make identification your main vulnerability strategy

If you want best outcomes for all customers for least cost and risk, lay an inclusive baseline first. Too many firms get this wrong.



Consider this 10 point checklist when conducting research with people in vulnerable situations

Summarising our learning from research projects with people in vulnerable circumstances to help fellow practitioners tackling similar challenges.



Beyond words

The written word dominates how we communicate on the web, but many of us struggle with it. This makes understanding financial services even harder. We need more than words if we want to treat everyone fairly.



Designing a chat service for people in crisis

Our strongest assumptions can vaporise on contact with service users. Learn how we helped Samaritans spot a hidden problem with their new service before it launched.



It's time for a different approach to design in financial services

When risk of buyer's remorse is high, getting product selection right requires a different mentality and different tools from the 'don't make me think' approach that most UX follows.



Why are customers ignoring offers to help?

Financial services firms urgently need to talk to their most vulnerable customers. But often those customers don’t trust them enough to respond. How can you fix a broken dialogue?



Inclusive design reveals ‘hidden’ problems

Many services have barriers to use that are invisible to the people who build them. It's time to start listening to a more diverse cross section of users.