Vulnerable Customer Policy & Procedures Playbook

Are you confident your firm can demonstrate compliance with the FCA's vulnerable customer expectations?

The FCA's March 2025 multi-firm review found that less than half of firms had formal governance bodies overseeing vulnerable customer outcomes. Only 54% of firms trained non-frontline staff on how vulnerability relates to their roles. And only four in ten consumers with vulnerability characteristics had disclosed their circumstances to their provider.

If your firm cannot clearly define what a good outcome looks like for a vulnerable customer, you are already behind the regulatory curve.

This Playbook bridges the gap between regulatory expectation and operational reality.

What You Get

A comprehensive Word document (30+ pages) that gives you a fully structured, ready-to-customise vulnerable customer policy and procedures framework, including:

• Document Control and Version History templates for audit trail and governance
• Full regulatory framework mapping (FG21/1, Consumer Duty, SMCR, SYSC, Equality Act 2010)
• FCA's four drivers of vulnerability explained with practical characteristics and examples
• Governance and Accountability framework with SMCR role mapping and Terms of Reference for a Vulnerable Customer Governance Forum
• Identification procedures covering all six FCA-recognised methods, with staff conversation prompts and empathetic questioning techniques
• Recording and Data Management standards, including a ready-to-use Vulnerability Record Template and UK GDPR considerations
• Flexible Customer Support procedures with an escalation matrix (Levels 1-4)
• Power of Attorney and Bereavement process requirements (reflecting the FCA's 2025 review focus)
• Inclusive Product Design framework with a Product Review Checklist
• Communication standards aligned to the FCA's findings on accessibility and digital exclusion
• Staff Training and Competence matrix by audience, content, frequency, and delivery method
• Monitoring and Outcomes framework with MI categories, metrics, and an Outcomes Monitoring Checklist
• Third-Party and Outsourcing management standards
• Complaints Handling provisions for vulnerable customers
• Review and Assurance programme, including regulatory preparedness guidance
• Key Contacts directory and External Resources signposting list
• Nine ready-to-use appendix templates

Who This Is For

• Compliance Officers and Managers responsible for vulnerable customer policy
• MLROs who need to consider vulnerability in the context of financial crime reporting
• Senior Managers under SMCR who hold accountability for customer outcomes
• Risk and Governance professionals
• Product and Service Design teams
• Customer Service and Operations leaders
• Firms preparing for FCA supervisory engagement or Section 166 reviews

Why This Playbook

• Aligned to the FCA's March 2025 Vulnerable Customer Review findings and good practice examples
• Structured around the Consumer Duty's four outcomes
• Maps SMCR accountability to vulnerable customer governance
• Includes practical templates you can implement immediately
• Written by compliance professionals who understand FCA expectations
• Designed to withstand regulatory scrutiny

Regulatory References

• FCA FG21/1: Guidance for Firms on the Fair Treatment of Vulnerable Customers (February 2021)
• FCA PS22/9: Consumer Duty (July 2023)
• FCA March 2025: Firms' Treatment of Customers in Vulnerable Circumstances - Review
• FCA March 2025: Delivering Good Outcomes for Customers in Vulnerable Circumstances - Good Practice and Areas for Improvement
• SYSC: Senior Management Arrangements, Systems and Controls
• SMCR: Senior Managers and Certification Regime
• Equality Act 2010

Format: Microsoft Word (.docx) - fully editable and customisable

Delivery: Instant digital download

Includes VAT at 20%. If you are a business and need a VAT Receipt, please ask.