Vulnerable customer policy template
A vulnerable customer policy sets out how your firm recognises customers in vulnerable circumstances and responds with appropriate care. This template follows the FCA's four drivers of vulnerability.
Why it matters
Vulnerability is widespread and can be temporary or permanent. Firms are expected to recognise it, respond with suitable support, and monitor outcomes for vulnerable customers, reinforced by the Consumer Duty.
What to include
Purpose and definition
Adopt the FCA's definition and the four drivers: health, life events, resilience and capability. State the policy's aim: good outcomes and no greater risk of harm.
Recognising vulnerability
How staff and systems spot signs, how disclosures are captured with consent, and how this is recorded sensitively.
Responding
The support options available (communication adjustments, extra time, forbearance, third-party support) and how staff are empowered to use them.
Training and culture
How staff are trained to have supportive conversations and to act on what they hear.
Record keeping and consent
What is recorded, how consent is managed, and how data is protected.
Monitoring
How outcomes for vulnerable customers are tracked against other customers, and how gaps are closed.
This template is general guidance to help you structure your own document. It is not legal, regulatory or compliance advice, and it is not a substitute for your own policies or professional advice. Adapt it to your firm, products and current regulatory requirements.
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