Supporting vulnerable customers without weakening fraud controls
Publication date:
25 February 2026
Last updated:
25 February 2026
Sarah Durkin, Director of Investigations, Woodgate & Clark
In recent years, vulnerability in the claims process has become one of the most pressing issues for our industry. Over half of UK financial services customers are now considered vulnerable – that’s up from 44% in 2023 to 51% in 2024. And the number of customers with mental health conditions has nearly doubled in just one year, from 10.2% in 2023 to 19.5% in 2024.
For claims professionals, this creates a real dilemma: how do we balance empathy and duty of care with the need to remain vigilant against fraud? How do we ensure the right support for genuinely vulnerable customers, while protecting the market from those who might exploit the system?
To help answer these questions, Woodgate & Clark hosted two webinar sessions with CII to gain perspective of claims professionals and vitally, those with first-hand experience of neurodiverse conditions.
We wanted to understand how undisclosed vulnerabilities, such as dementia, can emerge during the claims process and what our duty of care should be in these situations. We also sought to explore how insurers and their partners can validate vulnerabilities, such as neurodiverse conditions, that are disclosed in the middle of a fraud investigation. And we wanted to share experiences and best practices from across the sector on managing this complex balance between care, caution, and compliance.
We know that one of the main issues is that the indicators of vulnerability and fraud can sometimes overlap. Inaccuracies, inconsistencies or unusual behaviour may signal deliberate deception — or they may be the result of neurodivergence, dementia, anxiety or communication difficulties. Getting this distinction wrong can lead to poor outcomes for customers and reputational, regulatory and financial risk for insurers.
Recognising vulnerability early and consistently
What was clear from our discussion was that the earlier vulnerability can be identified the better, particularly as some claimants may not recognise or choose to share their vulnerability. To this end, one of the first steps for claims teams is for handlers and investigators to be trained to recognise signs of vulnerability. Typical signs may be confusion, difficulty processing information, memory lapses, or inconsistent explanations that do not appear intentional.
Flags for Vulnerability at FNOL
Clear, sensitive prompts at FNOL could also help encourage voluntary disclosure of neurodiversity or cognitive conditions. This would enable claims teams to adapt their approach from the outset.
Once vulnerability is identified or suspected, claims teams could then adapt how they engage. This may include:
· Simplifying language, using plain English while avoiding jargon and unnecessary acronyms
· Breaking down communications whether written or verbal into bite size pieces. AI tools can help here
· Asking about alternative ways the claimant would want to have information provided
· Offering more time for the claimant to respond to questions, possibly involving trusted support (such as a family member) with the claimant’s consent
These approaches may help vulnerable customers feel more comfortable which should help them provide accurate information without becoming overwhelmed or distressed.
Balancing fraud controls with fair outcomes
If a claimant is identified as genuinely vulnerable after a fraud flag has been raised using controls such as investigation triggers, there should be a clear “exit” back to the standard claims pathway and fraud investigators should also assess where any inaccuracies stem from.
Inevitably there will be cases where an individual is both vulnerable and suspected of fraud. In these instances it is essential that claims teams mark claim files with clear indicators of vulnerability to ensure continuity if cases are reassigned. They should also respect privacy by limiting access to sensitive information to those directly involved.
Where traditional forms of verification are difficult, guidance should be available on alternative evidence sources and investigative approaches.
Knowledge Sharing
Regular knowledge-sharing sessions among claims handlers and investigators is essential to reduce errors, challenge assumptions and learn from both successes and mistakes. At the same time there needs to be collaboration on best practice across the wider industry — including insurers, loss adjusters, fraud specialists and technology partners. This can help protect vulnerable customers while maintaining market integrity.
More than compliance
Fundamentally, supporting vulnerable customers without compromising the effectiveness of fraud prevention means being alert and adaptable: combining empathy with vigilance, tailoring investigations to individual circumstances, and ensuring that genuine customers are supported while fraud is still deterred.
Part 1 – Vulnerability - navigating the fine line between care and caution in claims