What is a vulnerable customer?

A vulnerable customer is someone whose personal circumstances make them especially likely to suffer harm, particularly if a firm does not take appropriate care. Vulnerability can come from health, a life event such as bereavement or job loss, low financial resilience or low confidence. It is often temporary, and often unspoken. AI agents must be built to notice it.

Why does vulnerability matter once agents act?

A trained member of staff picks up on hesitation, confusion or a passing remark and adjusts: slows down, checks understanding, offers more time or a specialist. An AI agent does none of that unless it is designed and tested to. Left to its defaults, it will treat a customer who has just been bereaved exactly like any other, process the request efficiently and move on.

Regulators expect firms to deliver good outcomes for vulnerable customers as well as others. In the UK, the FCA's Consumer Duty makes this part of the firm's core obligations, explained in our piece on FCA Consumer Duty, vulnerable customers and AI agents. That is why we hold that vulnerable customers need a person sooner, not later.

How do firms identify and support vulnerable customers in practice?

Identification usually comes from what customers say, what their account shows and how they interact. Common indicators include:

• Mentions of illness, disability, bereavement, relationship breakdown or job loss.
• Signs of confusion, repeated questions or difficulty following steps.
• Financial signals such as missed payments after a long good record.
• Someone else speaking on the customer's behalf.

Support then means adapting: more time, simpler communication, a specialist team, alternative channels, and recording the need, with consent, so the customer does not have to explain again. The vulnerable customer handling checklist turns this into steps.

An example from a lender's support chat

Take a lender whose agent is helping a customer change their payment date. Midway, the customer writes: "Sorry if I'm slow, my husband used to deal with all this and he passed away last month." The agent's handling of payment dates is fully certified. It stops anyway.

It acknowledges what the customer said with approved, plain wording, offers to connect them with a specialist team that can help with the account and a bereavement, and asks if they would prefer a call. It passes the conversation with a note. It does not record the bereavement as a permanent flag without the customer's agreement. Whether an AI agent can help a vulnerable customer depends on exactly this kind of early, gentle handover.

How is a vulnerable customer different from a customer in financial difficulty?

Financial difficulty is a specific situation: a customer is struggling or unable to meet their payments. It has its own rules in many markets, such as forbearance and affordable repayment plans.

Vulnerability is broader. A customer in financial difficulty is often vulnerable, but a vulnerable customer may be financially comfortable: someone newly diagnosed with a serious illness, or an elderly customer being pressured by a relative. An agent tested only on financial difficulty triggers will miss many vulnerable customers.

Which terms sit next to vulnerable customer?

• Consumer Duty: the FCA's requirement to deliver good outcomes for retail customers, including those in vulnerable circumstances.
• Third-party authority: someone authorised to act for the customer, such as under a power of attorney.
• A customer reporting fraud is often vulnerable in that moment, whatever their usual circumstances.
• A support agent that knows when to say no knows when to step aside.