Context
The Chartered Insurance Institute (CII) says customer vulnerability management is an opportunity for firms, rather than a cost, in its latest ‘Road to Consumer Trust’ report, which sets a ‘proportionate, practical approach’ to vulnerability management and outcomes monitoring.
Key points to note and next actions
The new CII Consumer Duty, Proportionality and Vulnerability Management for Financial Planning Firms Roundtable summary report shares the findings of regulatory specialists, financial planning leaders, compliance experts, and vulnerability practitioners.
The report suggests that effective vulnerability management can support firms in expanding their potential client base, reducing the cost of ad-hoc vulnerability handling, evidencing value to clients and regulators, and building long-term consumer trust.
With ‘demonstration of how firms are delivering good customer outcomes’ identified as a key supervisory priority for the Financial Conduct Authority (FCA) in 2026, roundtable participants outlined four core principles for determining the right proportional level of Consumer Duty implementation and vulnerability management: size of firm; role in distribution chain; characteristics of client base; and risk level of product or service.
The report concludes that firms should measure the same outcomes for vulnerable and non-vulnerable clients, and track the additional support provided to achieve those outcomes. Evidence of good outcomes throughout the journey, not just at the endpoint, and building robust vulnerability data infrastructure were recognised as essential prerequisites for meaningful outcomes comparison.
It also outlined three key indicators of when firms may not be doing enough to effectively manage vulnerability. These include a ‘one-size-fits-all’ vulnerability process, cultural resistance, and opaque outcomes monitoring systems that cannot identify whether different client groups are receiving good outcomes. Recommendations involve building strong data foundations, embedding inclusive design, and addressing cultural fears around vulnerability.