Supporting vulnerable customers after a protection sale
Vulnerability is common and often temporary. Post-sale support needs to work for customers at their least able, not just their most.
What vulnerability means
The FCA describes 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. Its guidance, FG21/1, groups the drivers into four areas: health, life events, resilience and capability. Many customers will experience one or more of these at some point, and circumstances can change quickly.
Why protection customers are particularly relevant
People often buy protection at moments of change, such as a new home, a new baby or after a health scare. They may claim at moments of crisis, such as serious illness or bereavement. And the cover itself is complex. All of this means distributors are likely to have a meaningful number of customers who are, or will become, vulnerable.
Signals after the sale
Some indicators appear in post-sale contact: a customer who mentions a recent bereavement, illness, job loss or money worries; difficulty understanding documents; repeated failed payments; or a request for help in a different format. Structured journeys can include an optional question asking whether the customer would like extra support, and route those who say yes to a trained person.
Adapting communications
The guidance expects firms to consider how communications work for different customers. Plain language, short steps, the ability to respond in one's own time and a choice of channel all help. Some customers prefer a digital journey because it avoids a stressful phone call. Others need to talk to a person. Offering both, and making it easy to switch, supports a wider range of needs.
Failed payments and affordability
A failed payment can be the first sign of financial difficulty. Rather than simply chasing payment, contact should acknowledge that the customer may be struggling and offer options, such as reducing cover, if the insurer allows it. Losing cover entirely can be a significant harm for someone whose circumstances have become more fragile.
Recording and sharing
Where a customer shares information about their circumstances, record it appropriately and with consent, so they do not have to repeat it. Make sure the people who need it, such as the adviser or claims support team, can see it. Review records periodically, as many vulnerabilities are temporary.
Monitoring outcomes
The Consumer Duty expects firms to check that customers with characteristics of vulnerability receive outcomes as good as other customers. For post-sale support, that might mean comparing response rates, issue resolution times and cancellation rates for customers who have asked for extra help against those who have not, and acting on any gaps.
Training and confidence
The people who handle routed responses need to feel confident responding to customers who share difficult circumstances. Training on recognising signs of vulnerability, responding with empathy, knowing what support is available and when to refer to specialist help makes a real difference. So does clear guidance on recording information and on what the customer can expect next.
Claims support
Vulnerability is often most acute at the point of claim. Customers who are seriously ill, or families who have been bereaved, may struggle with forms and evidence. Distributors can help by making sure customers and their families know how to claim, keeping trust and beneficiary details up to date, and offering to liaise with the insurer on their behalf. Many insurers also offer dedicated support teams and services for claimants.
Designing journeys for everyone
Designing post-sale journeys with vulnerable customers in mind improves them for everyone. Short steps, plain language, clear next actions and an easy route to a person reduce effort for all customers, not only those who are struggling. Testing journeys with a range of customers, and monitoring where people drop out, helps identify barriers that might otherwise go unnoticed.
Questions to ask of your own process
Can a customer tell you, easily and without a phone call, that they need extra support? Do the people who handle responses know what to do next? Is the information recorded so the customer does not have to repeat it? Do you compare outcomes for customers who asked for help with those who did not? Each 'no' is a practical place to start.
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FCA: FG21/1, guidance on the fair treatment of vulnerable customers
FCA: FG22/5, final guidance on the Consumer Duty
Adviser.ai figures are drawn from anonymised client data and are illustrative. Results vary by firm, product and implementation.
Last updated 27 October 2026