THE PROBLEM

Why are firms still struggling with vulnerability?

Vulnerability frameworks are well established. Consumer Duty has sharpened the focus further. Yet the FCA’s 2025 review found the same failure patterns repeating across firms of all sizes.

The core issue is about what happens in the moment: when a customer’s circumstances are ambiguous, when they don’t volunteer information, when a colleague has to decide in real time how to respond.

This is a judgement problem.

And e-learning modules do not build judgement.

44%

of vulnerable customers reported a negative experience — compared to 33% of others

42%

of vulnerable customers disclosed their circumstances to a firm — most did not

25%

were uncomfortable disclosing at all — the conversation has to earn it

Source: FCA Consumer Research.
Published with the March 2025 Vulnerable Customer Review

THE CONTEXT

Moving beyond accessibility to inclusive design

Most firms now recognise the importance of accessibility in customer journeys. But anticipating the needs of vulnerable customers requires moving beyond accessibility.

To clarify what the Financial Conduct Authority now expects, we spoke with Merlyn Holkar from the FCA and Paul Davies from Behaviour Consulting. The discussion considers how inclusive design can both improve outcomes for vulnerable customers and create opportunities to innovate.

RESERVE YOUR PLACE

Get ideas for inclusive design in your business

We send out a monthly round-up of inclusive design activity from across the financial services sector.

When you sign up, you’ll also receive a free copy of our white paper. This explains how scenario-based training can remove barriers for vulnerable customers.

Get some fresh ideas

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If you try one thing to implement inclusive design...

Here are some ideas shared by delegates at our inclusive design conference:

Run an inclusive design sprint

Run a one-day design sprint with people from product, marketing, comms, data and customer service, all working on one scenario from first contact to outcome. This will reveal the cross-functional factors that produce cognitive load, and enable teams to identify ways of reducing barriers for customers.

Investigate disclosures and complaints

Ask your product team what they learned last quarter from disclosures and complaints. If that insight stops at the contact centre, your products are being designed without it.

Identify the stakeholders you can't reach

If you know a particular process is creating a lot of friction, identify the stakeholders involved. Go and find the people who are hard to reach and buy them a coffee. Talk to them to understand their context, and listen to the challenges they face. This can reveal invisible barriers to inclusive design.

Explore the potential of inclusve matrix teams

Create matrix teams where a protected share of people’s time is dedicated to inclusive design of customer journeys. This can bring efficiencies and prevent the problem of inclusive design competing with business as usual for attention.

Verify whether comms have been tested by lived experts

Take the last three customer communications your team signed off and check whether anyone with lived experience of vulnerability read them before they went out. Testing a document with the people it is meant for before the document is approved can help remove problematic language before it creates a barrier.

Check whether incentives are working for or against inclusivity

Ask a product or proposition team what happens when they delay a launch to fix a problem for a small group of customers. Their answer tells you whether your incentives and your policy are asking for the same behaviour.

EXPERT PANEL

Who was involved in our conference?

We brought together practitioners who have direct experience of designing, implementing and auditing vulnerable customer programmes in financial services.

Faith Reynolds

Devon Fields Consulting

Vanessa Barnes

Women’s Wealth Alliance

Helen Pettifer

Helen Pettifer Training

Andy Harrison

Fidelity

Michael Hilton

Three Hands Insight

Carl Lyon

Fellowship of Responsible Business

Helen Bellamy

Quilter

Jaypee Soule

PensionBee

Carolyn Delehanty

Delehanty Consulting

Damian Chapman

Kingston University

Kathryn Townsend

Nationwide

Matt Robinson

Independent Consultant

Merlyn Holkar

Financial Conduct Authority

Paul Davies

Behaviour Consulting

Reuben Gustoni

Legal and General

Guides and links to help you with inclusive design

We’ve put together a list of resources that can give you ideas for using inclusive design in financial services.

Women's Wealth Alliance Career Guide: Your Career in Personal Finance

As financial expert Vanessa Barnes mentioned at our conference, only 18% of financial advisors are women. This factor alone creates barriers to engagement with financial products and services. This guide sets out a career path for women interested in becming financial advisors.

Building Confidence and Control in Digital Payments.

Devon Fields Consulting: Building Confidence, Control and Connection in Digital Payments

Faith Reynolds sets out a model for improving collaboration regarding digital payments across the financial services sector. Her report explains how increasing confidence, connection and control over payments can remove barriers to financial management through inclusive design.

Ding Learning: How Scenario Based Learning Improves Capability for Supporting Vulnerable Customers

Ding Learning use inclusive design to help businesses identify and remove barriers for vulnerable customers. In this white paper, we show how fictional scenarios create a safe space for testing out ideas. This improves the capability for designing more inclusive customer journeys.

Use cases for scenario-based design

Training Sales Teams

Improving product knowledge at IO-Sphere

Read Case Study

Creating Applied Learning

Improving apprenticeships at Multiverse

Read Case Study

Leveraging Video

Providing flexible access and participation at Measurelab

Read Case Study

“Working with the Ding team was such a pleasure… they made our content so much more relevant and engaging. We’ve had great feedback from both learners and coaches.”

Christine Doonan

Learning Designer, Multiverse