Tue 25 Nov. 2025
New CII guidance sets benchmark for managing vulnerability across insurance and personal finance
At a press event in central London this morning, the Chartered Insurance Institute (CII) announced the launch of a landmark guide to help insurance and personal finance firms to better identify, support, and deliver fair outcomes for customers in vulnerable circumstances.
The Managing Customer Vulnerability in Insurance and Personal Finance: A Practical Implementation Guide, which provides actionable direction on translating regulatory principles into practice was presented to an audience of around 50 press and other stakeholders by Adam Harper, Director of Strategy, Advocacy and Professional Standards at the CII; Andrew Gething, Managing Director at Morgan Ash; Claire Massey, CEO of Claims Guardians; Eddie Grant, PFS Board member, and Disability Access Ambassador for Insurance; Jonathan Pearson, Head of Consumer Policy and Outcomes at the FCA; and Vanessa Riboloni, Head of Research and Insight at the CII.
Up to half of UK adults show characteristics of vulnerability at any given time, and most will experience vulnerability at some point during their lives. As a result, firms that fail to manage vulnerability effectively are unlikely to meet the Financial Conduct Authority’s Consumer Duty obligation of providing good outcomes for all customers.
This unique guide includes practical resources to help firms translate regulatory intent into measurable action.
Key features of the publication:
- A six-step vulnerability management framework: identify, quantify, monitor, support, adapt and report
- A strong focus on data infrastructure and outcomes reporting, addressing areas of improvement identified in recent Financial Conduct Authority reviews.
- Guidance on the enabling elements required for successful vulnerability management including leadership commitment, training effectiveness and good practice for data sharing.
- Implementation pathways with proportionate approaches for firms of different sizes and complexity.
- Practical tools including checklists, case studies, and system selection criteria.
The guide has been developed in collaboration with vulnerability experts, customer experience practitioners, and individuals with lived experience of vulnerability. It offers actionable recommendations for firms of all sizes, and across the value chain.
Matthew Hill, Chief Executive of the CII, commented: “The CII Group is delighted to share this guidance with insurance and financial planning firms and professionals. Effective vulnerability management is about more than regulatory compliance. It is about creating a fairer, more resilient system for all customers. In embedding the principles of this guide into their culture and operations, firms will not only meet the expectations of good practice, but also contribute to the development of a sector that conscientiously strives to meet the needs of every customer.”
Carla Brown, President of the PFS, said: “I welcome this guidance as a significant step forward for our profession. Supporting clients in vulnerable circumstances is fundamental to good financial planning, and this practical framework gives firms clear direction on how to embed that responsibility into everyday practice. Our community is committed to raising standards and ensuring that every client, whatever their situation, receives the care, understanding and outcomes they deserve. This publication will help professionals across the sector strengthen their approach and, ultimately, deliver better experiences for the people who rely on us most.”
Claire Massey, founder of Claim Guardians, said: “As both a compliance professional and someone who has personally experienced vulnerability through the insurance process, I am proud to have contributed to this guidance. It represents a meaningful step forward in helping firms translate regulatory expectations into real empathy, fair decision-making and timely action. Vulnerability is not a theoretical concept; it’s a lived reality that can affect any of us overnight. This guide ensures that when things go wrong, customers in vulnerable circumstances are supported and not further disadvantaged by the very systems designed to protect them.”
Johnny Timpson, Chairman of Absolute Military, said: “As a Financial Inclusion Commissioner and as Chair of specialist armed forces broker Absolute Military I welcome the Chartered Insurance Institute’s Vulnerable Customer Guidance that supports the ambition of the Government’s Financial Inclusion Strategy and FCA Consumer Duty Regulation. I’ve long held that the test of our progress as an industry and profession together with the delivery of our professional body’s Royal Charter promise should not simply be measured in adding to the abundance of those we serve and/or improving their resilience to perils and shocks but importantly, in ensuring that the vulnerable customers we serve enjoy the same access, inclusion, protections and outcomes as anyone else.”
Eddie Grant, UK Cabinet Office Disability and Access Ambassador (Insurance and Financial Planning), said: “As the UK Cabinet Office Disability and Access Ambassador for the Insurance and Financial Planning sector, I welcome the publication of the Managing Customer Vulnerability guide - a timely and practical resource that supports firms and individuals in embedding inclusive practices and responding meaningfully to vulnerable client circumstances. It is a great example of the Professional Body convening power, bringing together a diverse range of expertise for the benefit of wider society.
This guide offers actionable steps that firms of all sizes can take to better understand, anticipate, and meet the needs of customers who may be at greater risk of harm. I am particularly encouraged by the guide’s emphasis on enabling elements and proportionate approaches building trust, removing barriers and ensuring that everyone can access the financial services they need to thrive. I urge our members and beyond to read, share, and implement the insights in this guide.”
The CII is convening a cross-sector taskforce to address technical challenges with data sharing across the profession, with further guidance on AI use and UK GDPR compliance to follow. In early 2026 it will also offer training and CPD modules on managing vulnerability, including an interactive online training session on 26 February for team members who are responsible for implementing the vulnerable customer framework within the business.