FCA Priorities: Vulnerable Customers and Financial Communications

The FCA continues to place significant emphasis on ensuring that customers are not just provided with information but are genuinely able to understand and engage with it. Under the Consumer Duty, vulnerability is framed broadly and extends beyond obvious life events to include capability characteristics such as low confidence, limited numeracy, or difficulties interpreting complex financial information. These factors can materially affect how clients interact with financial services and the decisions they make. 

FCA research illustrates the scale of this issue:

• Around 60% of adults in the UK show at least one characteristic that could make them potentially vulnerable.
• Approximately 19% of adults report challenges with financial knowledge or confidence, including low literacy, numeracy or digital skills.
• Customers in potentially vulnerable circumstances are more likely to struggle with understanding financial communications, and fewer than half disclose their needs to providers.

These findings highlight that vulnerability is not a marginal issue but a mainstream feature of the financial services landscape. Importantly, vulnerability is often situational and fluid. Individuals who are financially sophisticated in one context may experience reduced capability or confidence in others, particularly during periods of stress, complexity, or change.

A further behavioural dimension is increasingly recognised across the financial services sector. Many customers engage with financial information using rapid, intuitive (“fast”) thinking, while financial services communications are often designed on the assumption of deliberate, analytical (“slow”) processing. This mismatch can create a gap between what firms intend to communicate and what customers actually absorb, particularly where information is dense, technical, or heavily numerical.

The FCA’s evolving guidance reflects this broader understanding of customer behaviour and capability. Rather than focusing solely on disclosure, the regulator is increasingly concerned with how information is experienced in practice, and whether it supports effective decision-making. This has implications not only for regulatory compliance, but also for how firms think about transparency, accessibility, and client engagement more generally.  

From a financial services perspective, these themes are particularly relevant in areas such as private wealth, where reporting, portfolio information, and projections can be complex and data-heavy. Even highly engaged clients may encounter challenges interpreting information at certain moments, underscoring the importance of understanding how communications are received, not just how they are drafted. 

More broadly, the FCA’s focus on vulnerability and comprehension signals a continuing shift in regulatory expectations. Firms are likely to face ongoing scrutiny not only in relation to the content of their communications, but also in relation to how those communications are understood across diverse client groups. Awareness of these trends enables teams to stay aligned with regulatory thinking and to better anticipate the issues that may arise as the Consumer Duty continues to mature.  

Key reflections

• Vulnerability is widespread, dynamic, and not confined to traditionally defined groups.
• Behavioural factors, including the gap between “fast” and “slow” thinking, are increasingly relevant to how financial information is understood.
• The FCA’s emphasis on comprehension represents a broader shift from disclosure-based regulation to outcome-focused expectations.

Understanding these developments is essential for interpreting how regulatory priorities may shape financial services practice in 2026 and beyond. 

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