The FCA's Vulnerability Review: What It Means for Product and Proposition Design.

Published: 2024  |  Perspective updated: 2025

In March 2025, the FCA published the findings of its review into how firms are treating customers in vulnerable circumstances — a review that had been running throughout 2024, drawing on data from 725 firms and direct consumer research with 1,500 people.

The headline finding was measured but clear: progress has been made, but the gap between what firms are doing and what vulnerable customers are actually experiencing remains significant.

The FCA found that Consumer Duty has driven a renewed focus across firms on delivering good outcomes for vulnerable customers — and many had taken positive steps, including tailored communications, flexible support processes, and improved staff training. That is genuine progress and worth acknowledging.

But the review also found that consumers in vulnerable circumstances — particularly those with multiple characteristics of vulnerability — continue to experience worse outcomes than other customers. And two specific areas were flagged as needing more work: product and service design, and outcomes monitoring.

The disclosure gap

One of the more striking findings was about disclosure. Only four in ten consumers with characteristics of vulnerability have disclosed their circumstances to any of their financial services providers — and of those who did disclose, only around half were actively encouraged to do so. Around a quarter said they felt uncomfortable explaining their situation.

This matters enormously for how firms approach vulnerability. If the model relies primarily on customers self-identifying and then receiving support, it will consistently miss the majority of people who need it. Not because they do not want support, but because they do not feel able to ask for it, or because the organisation has not created conditions where asking feels safe.

Those who did disclose, however, mostly reported positive experiences. This suggests the problem is not primarily what happens once a firm knows about a customer's circumstances. It is the gap before disclosure — and building the trust and the systems that close it.

The product design gap

The finding I find most significant — and most directly relevant to the proposition design work I do — is the FCA's observation that product and service design remains an area where firms are yet to make significant progress. The regulator expects firms to design products and services to avoid potential harmful impacts and to meet the needs of customers in vulnerable circumstances — not just to offer bespoke support after the fact.

This is a meaningful distinction. Designing for vulnerability from the outset is fundamentally different from building a standard product and then adding an accessibility overlay. The former produces services that work better for everyone — because the constraints that make a product difficult for vulnerable customers often make it unnecessarily complicated for other customers too. The latter produces patchy, inconsistent support that depends on vulnerable customers being identified and routed to specialist teams.

Inclusive design from the outset is better design. The FCA's review makes this expectation clearer than it has been before.

The monitoring gap

The third area flagged was outcomes monitoring. The FCA found that many firms have underestimated the depth of monitoring required, or focus on measuring process outputs rather than actual customer outcomes. Monitoring that a process was followed is not the same as monitoring whether that process produced a good outcome for the customer at the end of it.

This is a harder problem than it sounds. Good customer outcome data requires investment in the right data collection, the right analytical frameworks, and the willingness to use findings that may be uncomfortable. It also requires a clear definition of what a good outcome looks like — which is the prior question that many firms have not answered as precisely as they need to.

Three things this means in practice

For anyone working in customer strategy, product design, or proposition development in financial services, the review points to three clear priorities.

First, build a clear customer impact measurement framework — one that goes beyond process metrics and captures whether the products and journeys you have designed are actually delivering the outcomes you intended for all customers, including those in vulnerable circumstances.

Second, embed vulnerability consideration in the proposition development process from the start — not as a compliance checkpoint at the end, but as a design lens from the first stage of defining what you are building and who it is for.

Third, design for inclusion from the outset — map your journeys, services, and product designs with the full range of customers in mind, not just the easiest ones. The regulator is watching. More importantly, the customers who need you most are the ones you most risk losing if this is not done well.