The PIMFA Customer Vulnerability Learning Programme 2026

Many firms have well-intentioned initiatives to vulnerability but fail to develop a robust strategy that stands up to regulatory scrutiny.

The FCA expects firms to ensure that:

1. customers in vulnerable circumstances have outcomes as good as non-vulnerable customers

2. staff understand the scale and nature of vulnerability in their customer base and target market

3. an informed and consistent approach to vulnerability is embedded in a firm’s policies, practices, and culture.

In this session you’ll establish how to practically achieve this in your own organisation by:

1. identifying and defining the FCA’s specific expectations around vulnerability

2. explaining how other legal and regulatory frameworks interact/relate to the FCA’s expectations

3. introducing a resource to estimate the size/type of different vulnerable customer groups

4. sharpening your analytical skills by exploring case-studies of how leading firms have created their vulnerability strategy frameworks

5. sharing and applying a tool to understand and repeatedly embed vulnerability into your organisational culture

6. unpacking ‘vulnerability language’ and definitions into operational/measurable actions.

In addition, we will also have our first spotlight discussion on:

• consumers experience of vulnerability in relation to investment services and advice

And by the end of this session, you will have:

1. insight into how firms (small and large) have approached the topic of vulnerability

2. heard from advisers and firms who have worked on strategy, culture, and understanding

3. spoken with at least one consumer with lived experience of vulnerability to gain additional insight.

Effective monitoring, evaluation, and management information (MI) are crucial for delivering good outcomes for vulnerable customers.

The FCA expects firms to:

1. collect relevant vulnerable customer outcome and experience data

2. build specific capacity in frontline, digital, quality assurance, and complaints functions

3. use these data to compare and analyse vulnerable customers with non-vulnerable customers

4. take steps to prevent foreseeable harm and less favourable outcomes for vulnerable customers

5. use insights from these data to improve operations, communications, training, and design activity.

In this session, you’ll:

• co-design a ‘ready to use’ metrics and outcomes monitoring framework for vulnerability clients

• explore the meaning of ‘quality’ and ‘impact’ in relation to consumer vulnerability

• appreciate why financial and non-financial segmentation is key to vulnerability data analysis

• develop a quality assessment scorecard to evaluate staff handling of vulnerability interactions

• adopt and embed what industry leading firms are doing to measure experience and outcomes in your own firm.

In addition, we will convene our second spotlight discussion on:

• consumers experience of bereavement-related vulnerability and quality of service

By the end of this session, you will have:

• heard from, and spoken with, firms leading on outcome and experience metrics

• co-developed a framework for measuring experience and outcomes on vulnerability

• up-to-date knowledge of what the FCA expects on data collection, evaluation, and monitoring.

The need for firms to implement robust and consistent processes for identifying and recording customer vulnerability, ensure consistent application, and create an environment that encourages disclosure from vulnerable customers is greater than ever.

The FCA expects firms to ensure that:

1. they can consistently identify customers who are vulnerable to foreseeable harm

2. relevant staff can engage, start conversations, and understand these customers circumstances

3. where appropriate, individual and aggregate data can be used to identify customer vulnerability

4. practically relevant data are recorded in line with organisational and regulatory frameworks.

In this practical session, you’ll:

• reflect the practical expectations that the FCA have on identification and data recording across your people, systems and processes

• receive clear guidance on identification strategies for different staff, channels, and data-sets

• recognise the barriers and facilitators to consumer disclosure of vulnerability

• identify with greater clarity what consumers want from firms when they tell a firm about their vulnerable situation

• explore the different regulatory and legal frameworks related to vulnerability data recording.

In addition, we will hold our third spotlight discussion on:

• consumers experience of vulnerability related to harmful trading or gambling activity

By the end of this session, you will have:

• knowledge of how leading firms are training staff/using data to identify consumer vulnerability

• tools to build ‘disclosure environments’ that facilitate (rather than block) vulnerability disclosures

• a clear framework outlining the different legal and regulatory options on data recording.

Effective support for vulnerable customers requires a multifaceted approach that includes proactive identification, flexible and tailored support, clear and timely communication, staff training, and a commitment to incorporating customer feedback and lived experience into both service provision and product design.

The FCA expects firms to ensure that:

1. they can provide relevant, reasonable, required, and realistic support to customers

2. staff know what internal support is available (and ‘how far’ to go before external signposting)

3. support for consumers is also embedded/built into the design of advice and sales journeys

4. relevant options for third-party involvement and support are used where appropriate

5. staff understand the wider legal frameworks that relate to support (including, but not limited to, the Equality Act 2010 and Mental Capacity Act 2005).

In this session, you’ll:

• receive a comprehensive overview of the range of support needs that your firm can immediately put into place

• a battle-tested protocol that all your staff can use to establish quickly and effortlessly what support a consumer may need

• obtain a planning tool that will help your firm decide ‘how far’ to go with internal support provision

• get the perspectives and context you need to solve your toughest support challenges exploring case-studies of the approach taken by firms of differing sizes and service/product ranges

• grasp and embed the relevant regulatory and legal responsibilities your firm has on support.

In addition, we will have our fourth spotlight discussion on:

• consumers experience of vulnerability related to dementia and mental capacity

By the end of this session, you will:

• know how to provide relevant and timely ‘preventative’ and ‘in-response’ support to consumers

• have tools to plan and deliver a practical and understood consumer support strategy

• interacted and questioned at least one consumer about their experience of support from firms

• understood the wider regulatory and legal landscape on support, adjustments, and ‘extra help’.

Firms must have clear, timely, and accessible communications, adapted to meet the diverse needs of vulnerable customers.

The FCA expects firms to ensure:

• consumers understand the information and decisions they make about services and products

• communications use clear and accessible language (including figures/numerical information)

• known consumer behavioural biases are taken into account during consumer interactions.

• communication accounts for vulnerable consumers’ needs (including format or channel choice)

• checks are made during decision-making (including understanding, recall, and option evaluation)

• relevant data are recorded (and shared where appropriate) across any relevant distribution chain.

In this session, you’ll:

• identify a range of communication formats and strategies to improve understanding

• experience and test with rigour these formats and strategies through case-studies and simulations recognise how behavioural bias can inadvertently cause consumer detriment or harm
• replicate how leading firms are delivering multi-channel communication options to their consumers

• discover tools and processes for checking consumer decision-making at all stages of engagement.

In addition, we will have our fifth spotlight discussion on:

• consumers experience of vulnerability related to fraud and scams.

By the end of this session, you will:

• have a framework to develop, test, and improve accessible and ‘intelligible’ communications

• personally, experienced a range of different formats and options for accessible communication

• heard from leading firms about their communications process, successes, and set backs on

• have the tools and understanding you need to routinely check for informed consumer decision-making.

Firms need to move beyond reacting to problems to implementing preventative measures that actively protect vulnerable customers.

The FCA expects firms to ensure that:

• all journeys, interactions, services, and products are designed to meet need and prevent harm

• vulnerable consumers are considered at all stages of this process

• ‘vulnerability’ is embedded in idea generation, development, testing, launch and review stages

• design is an activity that applies to the advice journey and interactions within it.

In this session, you’ll:

• learn through inclusive design how organisations are firms are developing more diverse and inclusive products and services

• speak with consumers about their experience of positive and poorly designed interactions

• obtain a design toolkit and process to follow and apply within your own organisation.

In addition, we will have our final spotlight discussion on:

• consumers experience of vulnerability related to financial abuse involving family members.

By the end of this session, you will:

• heard from, and spoken with, firms leading on design within our sector

• explored a framework for designing journeys and interactions with vulnerability in mind

• up-to-date knowledge of what the FCA expects on design that meets need and prevents harm.