By Kevin Still
At the end of July 2025 a number of FCA directors reported on progress made in financial services since the Consumer Duty was implemented in July 2023. Alison Walters, Director of Consumer Finance, provided an update in which she looked at areas of progress under ‘creating better outcomes for people’, including around vulnerability management.
“The Duty required a fundamental shift in mindset, and two years on, we’ve seen real change across the sector – from lenders and credit brokers to debt collectors and debt advice providers.”
“This includes better identification of vulnerable customers where some firms now cross-check new customers against external vulnerability registers, helping them to ensure tailored support from day one.”
The Vulnerability Registration Service (VRS) is one of these external vulnerability registers that has been referenced by Alison at previous FCA events.
Many firms have redesigned consumer information and their websites to improve accessibility and intelligibility. The FCA has previously flagged challenges with low levels of literacy and numeracy, including English not first language. They are now looking at positive friction in customer digital onboarding journeys. API look-ups can be embedded in these journeys to identify recorded vulnerabilities on a ‘tell me once’ basis.
She has also referenced digital innovation, where firms like VRS have invested heavily in their digital offerings, providing online portals for customers to manage their accounts, and created solutions to help people check for additional benefits they may be entitled to with providers like InBest AI and Policy in Practice.
Improved partnership working has been crucial where VRS can signpost customers to debt advice or money health check services where needed, like StepChange Debt Charity, IE Hub or National Support Network (NSN).
VRS allows anyone to register for free so that the information can be shared with their service providers to act upon. Consumers can select from vulnerability flags to highlight how they are vulnerable – these flags include mental and physical health; financial difficulty and capacity; life events such as bereavement and providing unpaid care; accessibility issues ranging from hearing or sight impairment, dyslexia to technical capability.
Those who register can also use the service to communicate to service providers, how they can be helped e.g. their communication preferences or how they can be helped with financial management.
Cat Divers, Founder and CEO, National Support Network said:
“ When a customer registers their vulnerable circumstances, it is powerful to know that, in that very moment, they can be connected to trusted support to help them resolve or better manage their situation. We are proud to be working with VRS to extend their offering and help those in need.”
Post a comment