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New FCA guidance on vulnerable customers

News article

Publication date:

31 July 2020

Last updated:

05 August 2020


Policy and Public Affairs

The Financial Conduct Authority (FCA) announce new guidance for firms on the fair treatment of vulnerable customers.

The newly published guidance, GC20/3, is based on responses from the FCA’s initial consultation  where they set out their view on Principles for Businesses required of firms to treat vulnerable consumers fairly. By seeking views on this guidance, the FCA have considered feedback from professionals across the financial services sector on their concerns and experiences.


The FCA have decided on a two-stage approach so that they can consider responses to the original consultation alongside views on their updated draft Guidance (Annex 4) and Cost Benefit Analysis (CBA, Annex 3).


In light of their Business Plan for 2020/21, the FCA have recognised that the coronavirus has significantly increased the number and severity of issues affecting customers (eg ill health, bereavement and job loss), particularly those already with vulnerable characteristics. Addressing their commitment to vulnerable customers, the FCA said:

“During the period while this consultation was on hold, we have worked to understand the impact of coronavirus on consumers and how it affects vulnerability. We have engaged extensively with consumer partners and carried out research to understand the nature and scale of the impact on people’s financial lives.”


Through their research, the FCA have identified the following key areas that need to be achieved to ensure the fair treatment of vulnerable customers:

  • Outcome 1: consumers can be confident they are dealing with firms where the fair treatment of customers is central to the corporate culture.
  • Outcome 2: products and services marketed and sold in the retail market are designed to meet the needs of identified consumer groups and are targeted accordingly.
  • Outcome 3: consumers are provided with clear information and are kept appropriately informed before, during and after the point of sale.
  • Outcome 4: where consumers receive advice, the advice is suitable and takes account of their circumstances.
  • Outcome 5: consumers are provided with products that perform as firms have led them to expect, and the associated service is of an acceptable standard and as they have been led to expect.
  • Outcome 6: consumers do not face unreasonable post-sale barriers imposed by firms to change product, switch provider, submit a claim or make a complaint.


This new consultation will be of interest to the following:

  • all FCA-regulated firms to whom the Principles apply, and their appointed representatives
  • industry groups and trade bodies
  • consumer organisations and organisations that promote the interests of vulnerable consumers
  • consumers and consumer advisers


The deadline to respond to this stage of the consultation is 30 September 2020.

You can respond through one of the following methods:

Final guidance will be published sometime later in 2020 or early 2021.

This document is believed to be accurate but is not intended as a basis of knowledge upon which advice can be given. Neither the author (personal or corporate), the CII group, local institute or Society, or any of the officers or employees of those organisations accept any responsibility for any loss occasioned to any person acting or refraining from action as a result of the data or opinions included in this material. Opinions expressed are those of the author or authors and not necessarily those of the CII group, local institutes, or Societies.