Skip to content
Wealth Analytica logo

Regulatory · Vulnerable clients

Identification, recording, adaptation

The FCA's guidance on vulnerable customers — FG21/1 — has been live since 2021 and now sits inside the Consumer Duty's outcomes framework. The year-2 annual board report should report at segment level on how many clients have been flagged, in which driver categories, what adaptations have been made, and what the outcomes look like compared to the rest of the book. The most damning finding in any FCA review of an IFA firm is a report saying the firm has no vulnerable clients.

Vulnerability identification is partly process and partly skill. The process bit is the easier half — at every meaningful interaction the firm runs through the four drivers (health, life events, resilience, capability), asks the open questions that surface them, and records the answers in a structured field on the client record. The skill bit is harder. Hearing what's not said. Distinguishing a transient life event from an enduring vulnerability. Adapting without being patronising. The articles below are the practical guidance for the adviser doing the work.

The cluster anchors in FG21/1 and the FCA-ICO joint guidance on vulnerability data. Each piece carries a named author and reviewer and is refreshed quarterly. Read our editorial policy for the sourcing standards.

For the broader regulatory picture see the Regulatory hub. For the year-2 outcomes monitoring context see the Consumer Duty cluster.

About the authors

Eliot Jones (DipPFA, CCIBS) anchors the vulnerable-client cluster as a practising wealth manager with first-hand experience of the meeting-room work the rules describe. Matthew Hull (CFA, MSCI) reviews — bringing portfolio-construction perspective on how vulnerability flags should shape ongoing recommendation discipline.