The vulnerable customer gap: UK businesses committed to supporting customers, but three in four lack automated, searchable records for FCA evidence
– 98% say they’re prepared for the FCA’s increasing scrutiny of vulnerable customers
– Yet only a quarter (25%) have vulnerable customer interactions automatically logged and searchable, with the rest relying on manual notes, multiple systems or inconsistent records
– Nearly two-thirds (63%) would need three working days or more to retrieve a single interaction record for a regulator, and just 4% could do it the same day
Almost all UK retail and financial services businesses surveyed (98%) say they are prepared for the Financial Conduct Authority’s (FCA) increasing scrutiny of how they treat vulnerable customers, according to new research from customer experience specialist IP Integration (IPI). However, the findings show the systems used to automatically capture and retrieve records of those customer interactions aren’t keeping pace, meaning many businesses would need days rather than hours to show a regulator how a vulnerable customer was supported.
This comes as organisations face growing pressure to evidence how they support vulnerable customers. Under Consumer Duty, the FCA expects businesses to be able to demonstrate good outcomes for vulnerable customers, and being able to evidence how individual customers are treated is central to meeting that standard. New BNPL rules introduced in July extend those expectations to a payment option almost every business surveyed (99.5%) now offers.
The study, conducted with Cavell among 400 compliance, operations and customer operations leaders at UK retail and financial services organisations, shows how seriously businesses are taking this. 94% say readiness for vulnerable customer scrutiny has been discussed at board level in the last six months, and 99% have tested their processes against a mock regulatory audit in the past year. Compliance leaders, who work closest to the regulation, are slightly more cautious: 90% are confident they could provide evidence of a vulnerable customer interaction quickly, compared with 99% of operations leaders.
The gap between intent and evidence
The challenge is in how that evidence is captured day to day. A quarter (25%) of businesses have vulnerable customer interactions automatically logged and searchable. For the rest, records are:
√ logged manually by staff (27%)
√ spread across multiple systems (25%)
√ captured inconsistently (23%)
In practice, that can mean a team has to find and piece together a customer’s record by hand before it can be shared with a regulator. Nearly two-thirds (63%) say that would take three working days or more for a single interaction, while 4% could do it on the same day.
The same applies to spotting vulnerability in the first place. A third (33%) say frontline staff rely mainly on training and judgement to identify vulnerable customers during live conversations – a reflection of the expertise many organisations have built. Technology has a role to play in supporting that expertise: giving staff prompts and tools that make good practice easier to apply consistently, and that capture what happened as a matter of course.
BNPL adds another layer of complexity
Since July 2026, regulated BNPL lenders have had to assess affordability, support customers who fall into difficulty and demonstrate that they have done so. A single BNPL journey can span checkout, affordability checks, customer service and complaints, which means more touchpoints to capture and connect into one record. Ahead of the new rules, businesses were confident: 94% said they could quickly evidence a BNPL affordability or vulnerability decision. With the rules now in force, the focus shifts from confidence to execution, making sure every stage of that journey is captured, connected and shows the customer was supported appropriately.
Annabelle Goymer, Head of Customer Success at IPI, said:
“Anyone can become a vulnerable customer. A bereavement, a health problem or a sudden drop in income can change someone’s circumstances overnight, and FCA research shows only four in ten people tell their provider when it happens. That means businesses need to be well-placed to recognise the signs and respond appropriately – not wait for customers to identify themselves as vulnerable.
“The intent is clearly there, and businesses have invested in the policies and governance to back it up. The opportunity now is to make good practice easier on the frontline. That means giving workers prompts within the systems they already use, so spotting vulnerability doesn’t rest on memory or experience alone. It means capturing what happened automatically as part of the conversation, rather than relying on notes written up afterwards.
“But capturing interactions is only part of it. What regulators are looking for is evidence of good outcomes: that the customer was understood, supported appropriately, and left better off for the interaction. Get those foundations right and the evidence is there when the regulator asks. More importantly, the customer gets the right support first time.”
Founded in 2001, IPI is one of the UK’s longest-established customer experience specialists, helping organisations deliver exceptional customer contact for more than 25 years. IPI combines contact centre consultancy with its own technology, helping organisations redesign how they serve customers, adopt AI practically and get lasting value from their technology. IPI works with organisations across financial services, insurance, retail, utilities, travel, higher education and the public sector. Headquartered in Reading, IPI has offices in London, Manchester and the Philippines.
About the research: The findings are based on independent research conducted among 400 compliance, operations and customer operations leaders across UK retail and financial services organisations. Fieldwork was completed between 20 May and 1 June 2026. The research was conducted by Cavell, a member of the Market Research Society (MRS), and follows MRS and ESOMAR research standards and principles.
