Finance Editor, Kael Tripton Ltd - LBS MBA - Verified against FCA Handbook: 14 June 2026
Quick answer
Under FCA Consumer Duty Outcome 4 and Guidance FG21/1, all FCA-authorised insurers must identify and appropriately support vulnerable customers. If you have a health condition, are bereaved or have low digital capability, you can request adjusted support. Failure to provide it can be challenged through the insurer's complaints process and the FOS.
What Is a Vulnerable Customer Under FCA Rules?
Direct answer
What does vulnerable customer mean under FCA Consumer Duty?
The FCA defines vulnerable customers as those especially susceptible to harm due to personal circumstances. The four drivers are: health (physical/mental conditions), life events (bereavement, job loss), resilience (low financial resilience) and capability (low literacy or digital capability). Consumer Duty Outcome 4 requires every FCA-authorised insurer to identify and appropriately support vulnerable customers.
The Four FCA Vulnerability Drivers
| Driver | Examples | Insurance context |
|---|---|---|
| Health | Mental health conditions, cognitive impairment, serious illness | Difficulty understanding policy terms, processing claims documentation |
| Life events | Bereavement, job loss, relationship breakdown, new carer | Administering deceased estate, reduced income, stress impairing decision-making |
| Resilience | Low financial resilience, high existing debt | Limited ability to absorb premium increases or claim shortfalls |
| Capability | Low financial literacy, limited English, low digital access | Unable to manage online-only portals, difficulty comparing policies |
Disclose your vulnerability to the insurer
Tell the insurer about your health condition, bereavement, or other vulnerability at the outset of any claim or complaint. Most insurers have a dedicated support team.
Request adjusted communication
Ask for phone communication instead of digital-only, or for correspondence in larger print, or for more time to respond to requests.
Document the disclosure
Keep a record of when and how you disclosed your vulnerability. If the insurer subsequently fails to make adjustments, this documentation supports a complaint.
Complain citing Consumer Duty Outcome 4 and FG21/1
Write to the insurer's complaints team referencing FCA Consumer Duty Outcome 4 and FCA FG21/1.
Escalate to FOS
The FOS takes vulnerable customer treatment seriously and has awarded distress and inconvenience compensation where firms failed to adjust their approach.
Related KT guides
Frequently Asked Questions
What is a vulnerable customer under FCA Consumer Duty?
The FCA defines a vulnerable customer as someone who, due to their personal circumstances, is especially susceptible to harm, particularly when a firm is not acting with appropriate levels of care. The FCA identifies four drivers of vulnerability: health (physical or mental health conditions affecting ability to manage financial products), life events (bereavement, job loss, relationship breakdown), resilience (low financial resilience, high indebtedness), and capability (low financial literacy or digital capability).
What must home insurers do for vulnerable customers under FCA rules?
Under Consumer Duty Outcome 4 (Consumer Support) and the FCA's Guidance for Firms on the Fair Treatment of Vulnerable Customers (FG21/1), insurers must ensure their products, communications and services are accessible to vulnerable customers. This includes: offering alternative communication channels (phone rather than digital-only), providing information in accessible formats, training staff to identify and respond appropriately to vulnerability, and not creating barriers that disproportionately affect vulnerable customers when claiming.
Does bereavement count as vulnerability under FCA rules?
Yes. Bereavement is explicitly listed by the FCA as a life event that can create temporary vulnerability. If you are administering a deceased person's estate and need to deal with their home insurance claim, the insurer must treat you with additional care under Consumer Duty and FG21/1. You should inform the insurer of the bereavement at the outset -- this triggers their obligations to provide appropriate support and adjust their approach.
Can I complain if an insurer did not treat me as a vulnerable customer?
Yes. If you disclosed a vulnerability (health condition, bereavement, low digital capability) and the insurer did not adjust their approach accordingly, this may breach Consumer Duty Outcome 4 and FG21/1. Complain in writing citing Consumer Duty and FG21/1. If unresolved in 8 weeks, escalate to the FOS. The FOS considers vulnerable customer treatment in its decisions and has awarded compensation for failure to make reasonable adjustments.
What is the FCA FG21/1 guidance on vulnerable customers?
FCA Finalised Guidance FG21/1 (published February 2021, updated for Consumer Duty) sets out detailed expectations for how firms should treat vulnerable customers. It covers: understanding who may be vulnerable, skilled staff and appropriate culture, product and service design, communications, and monitoring outcomes. It is not a set of rules but the FCA uses it to assess whether firms are meeting their Consumer Duty and Treating Customers Fairly obligations.
Primary sources
Kael Tripton Ltd is registered with the Information Commissioner's Office under registration number ZC135439.
