Financial Conduct Authority guidance on supporting vulnerable people

Posted on Friday, 11 September 2026 by Henny Swan in Strategy

Tags: Corporate governance

If you work in financial services, you may be familiar with the UK Financial Conduct Authority's (FCA) FG21/1 Guidance for Vulnerable Customers which outlines what organisations should do to support vulnerable customers.

While targeted at FCA-regulated services, it's a useful set of guidelines for all organisations to keep in mind when supporting vulnerable customers, some of whom may also be disabled.

About the guidance

FG21/1 Guidance for firms on the fair treatment of vulnerable customers (PDF), or the guidelines, sets out how FCA-regulated organisations can support vulnerable customers. Organisations aren't required to adopt the guidance, but under Principle 6 of the FCA's Principles for Businesses every FCA-authorised organisation must treat customers fairly, including vulnerable customers. The guidance provides insights into how to do this.

Who it applies to

An FCA-regulated organisation is one the FCA authorises to provide financial products or services to consumers such as banks, insurers, investment companies, mortgage lenders, and consumer credit companies.

The overlap with digital accessibility

The guidelines state that organisations must:

...ensure communications throughout the life-cycle of a product or service are clear and provided to vulnerable consumers in a way that they can understand.

It then lists websites as an example of how organisations can put this into practice alongside accessible video using British/Irish Sign Language, simplified versions of communications such as infographics, accessible colour schemes, audio options, and more.

While it doesn't explicitly mention the Web Content Accessibility Guidelines (WCAG), it does state FCA-regulated organisations should ensure they are aware of the requirements of the Equality Act 2010 in the fair treatment of vulnerable customers and reasonable adjustments for people with disabilities.

The guidelines

Core to the guidelines is that organisations must demonstrate practical steps to support vulnerable customers rather than simply having policies in place. Organisations should then be able to show how they identify customer needs, train teams to support those needs, take on board customer feedback, and continuously monitor progress.

1. Understand the needs of vulnerable customers

The guidelines require organisations to understand who their vulnerable customers describing a vulnerable customer as:

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

It then groups characteristics of vulnerability into four areas where different types of disability feature heavily:

• Health: physical disabilities, long-term illness, mental health conditions, addiction, low mental capacity
• Life events: retirement, bereavement, income shock, relationship breakdown, domestic abuse, caring responsibilities, or other circumstances such as leaving care, migration, trafficking, convictions
• Resilience: inadequate or erratic income, over-indebtedness, low savings, low emotional resilience
• Capability: low financial knowledge or confidence, poor literacy or numeracy, poor English, poor digital skills, learning difficulties, low access to support

This applies to all of us. One or more of the above can affect us at any point in our lives as vulnerability, like disability, can be permanent, temporary, or situational.

2. Build team skills and capability

The guidelines state that organisations must support teams building the skills and capability to support vulnerable customers stating that:

...frontline staff have the necessary skills and capability to recognise and respond to a range of characteristics of vulnerability

From the boardroom through to product delivery every role has a responsibility in meeting the needs of vulnerable customers.

The board and senior leadership set the direction by ensuring accessibility governance is taken into account at the board level by setting out:

• What the organisation's accessibility obligations are
• Who in the organisation is accountable for accessibility
• How the organisation evidences they are meeting its obligations

Having accessibility governance in place helps create a culture of accessibility across all teams rather than it being perceived as a compliance burden for digital teams alone.

Ultimately however, there's a difference between knowing you need to be accessible and making it happen.

Most people working in digital roles have never been taught accessibility. It's something they're expected to pick up on the job, which means people may lack the confidence and skills to design for disability, and in particular design for people with anxiety and other conditions that make them vulnerable. Investing in training helps build the confidence and skills, meet the responsibilities of their role, and set them up to succeed.

Complementing building capability through training is accessible recruitment. By actively hiring people with accessibility skills, including people who are disabled and have lived experience, you ensure capability matures as teams grow and evolve.

3. Taking practical action

The guidelines state that organisations must take practical steps to ensure the needs of vulnerable customers are met:

...take vulnerable consumers into account at all stages of the product and service design process, including idea generation, development, testing, launch and review, to ensure products and services meet their needs.

Responding to customer needs means actively including vulnerable customers and people with disabilities in the design and development process as well as monitoring and actioning customer feedback.

Conducting user research with vulnerable people helps identify issues that might not get flagged by an accessibility assessment that centres on the WCAG. This is the ideal way to verify that your copy, components, and features are truly accessible, and don't unintentionally cause "harm" to your vulnerable customers. This is becoming increasingly important where Artificial Intelligence is being integrated into product delivery team workflows.

The Inclusive Design Principles are another useful tool. The principles are intended to work alongside WCAG by providing teams with a framework for deciding what features and user journeys remove friction and barriers.

One of the principles is especially relevant, Consider situation:

People use your interface in different situations. Make sure your interface delivers a valuable experience to people regardless of their circumstances.

Consider situation is a prompt to think about the context in which people are accessing your website or app. Perhaps people are on the move, under pressure, in a rush, feeling anxious, or confused. All things that can impact focus and decision-making.

4. Monitor and evaluate outcomes

With the appropriate governance, training, and processes in place to support vulnerable people, the guidelines state it is important for organisations to then monitor and evaluate progress:

Produce and regularly review management information, appropriate to the nature of their business, on the outcomes they are delivering for vulnerable consumers.

Many organisations choose to benchmark product accessibility with annual assessments. This has the added benefit of producing updated Accessibility Conformance Reports that evidence progress and highlight where products have not met the needs of vulnerable consumers, so teams can make improvements.

Alongside documenting product accessibility conformance through assessments, EN 17161 Design for All, the EU framework for embedding accessibility into strategy, recommends setting accessibility objectives, then tracking progress against these. This can be done by implementing accessibility Key Performance Indicators (KPIs) and putting in place product accessibility roadmaps, as well as tracking customer feedback through complaints, online reviews, social media, and customer satisfaction surveys.

Next steps

Read about sustainable accessibility and how to make lasting change in how you deliver accessible products. Or learn about how our self-led training courses and training programmes can help build accessibility skills and capability across multiple teams.