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FCA consultation on guiding firms on fair treatment of vulnerable customers

News Article

Publication date:

25 July 2019

Last updated:

12 December 2019


Policy and Public Affairs

The FCA have announced details of a consultation on proposed guidance for firms on the fair treatment of vulnerable customers.

This new consultation GC19/3: Guidance for firms on the fair treatment of vulnerable customers follows on from the FCA’s Approach to Consumers consultation paper in 2018, which set out their vision for a well-functioning market that works for consumers. One of the action points from this paper was to consult further on guidance for firms on the treatment of vulnerable consumers.

Many firms have already made significant progress on how they treat vulnerable customers, however the FCA believes there needs to be more consistency across financial services. In some cases, firms are clearly failing to consider the needs of vulnerable consumers, leading to harm.

Christopher Woolard, Executive Director of Strategy and Competition said:

“Protecting vulnerable consumers is a key priority for the FCA and we want to see firms explicitly embedding the fair treatment of vulnerable consumers into their culture. Where we find that firms are not doing enough to ensure that consumers are treated fairly, we will take action.

Firms need to take particular care to ensure that vulnerable consumers are treated fairly as they may be more likely to experience harm. The guidance should drive improvements across the industry, improving outcomes for millions of vulnerable consumers.”


The proposed guidance is in three sections:

  • Understanding the needs of vulnerable consumers.
  • Ensuring staff have the skills and capabilities needed.
  • Translating that understanding into taking practical action.


The guidance will be consulted on in two stages as follows:

Stage 1: Guidance on: 

  1. Whether the draft Guidance covers the right issues and would provide firms with the right degree of clarity on what they should do to improve the outcomes for vulnerable consumers.
  2. How this Guidance could affect firms’ costs and the extent of benefits to vulnerable consumers from changes triggered by the Guidance.
  3. We also want to hear stakeholders’ views on whether the Guidance, as part of the FCA’s regulatory framework, is sufficient to ensure firms take appropriate action to treat vulnerable consumers fairly, or whether stakeholders consider that we need additional policy interventions, such as additional rules, to ensure this happens.

Second stage: Consultation on revised draft Guidance following feedback from Stage 1, publishing a cost-benefit analysis alongside it.


The FCA are asking for responses by 4 October 2019.


post: Consumer Strategy Team, Financial Conduct Authority, 12 Endeavour Square, London, E20 1JN


You can also read the following publications from the Chartered Insurance Institute on vulnerable customers:

This document is believed to be accurate but is not intended as a basis of knowledge upon which advice can be given. Neither the author (personal or corporate), the CII group, local institute or Society, or any of the officers or employees of those organisations accept any responsibility for any loss occasioned to any person acting or refraining from action as a result of the data or opinions included in this material. Opinions expressed are those of the author or authors and not necessarily those of the CII group, local institutes, or Societies.


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