Following the publication of  the FCA’s fair treatment of vulnerable customers last year and the anticipated release of the Consumer Duty guidance, there is a clear emphasis on the need for firms to be able to identify and support vulnerable clients. However, the obstacles that exist in continuously recognising vulnerable clients and how to document actions taken,  around the four drivers of vulnerability (Health issues, Life Issues, Individual’s resilience, Individual’s capability), are not clearly articulated by the regulator. The purpose of this working group is to assist members, client firms and the FCA in setting a centralised understanding of what is meant and also achievable in the interpretation of the guidance.

Key areas of focus:

Verify regulatory requirements around vulnerability are feasible and achievable.

Improve understanding of FCA reporting requirements

How to record additional cognitive vulnerabilities (resilience and capability)

Establish the perimeter of client firm’s responsibilities

Gain agreement with FCA of APCC thought leadership of all of the above  in setting common standards


The Vulnerability working group will meet regularly, to discuss current issues and challenges in the industry, and look to engage with all relevant stakeholders. The group will circulates minutes in relation to these meetings to the APCC membership. Recent developments include the current and ongoing challenges caused by the Coronavirus pandemic will be a key part of the meetings.

If you would like to take part in the discussion and would like to be a member of this working group, please email

Working Group Team Leaders

Working Group Chair
Martin picture
Martin Schofield
Deputy Chair