Vulnerable Customer Marketing: What FCA Expectations Mean for Your Campaigns

The FCA defines a vulnerable customer as someone who, due to their personal circumstances, is especially susceptible to harm — particularly when a firm is not acting with appropriate levels of care. The guidance identifies four drivers of vulnerability that can affect anyone at any time.

Health: physical or mental health conditions that affect the ability to carry out day-to-day tasks, process information, or make decisions. This includes cognitive impairments, severe illness, mental health conditions like depression or anxiety, and addiction. Health-driven vulnerability is particularly relevant for marketing because it can affect how someone processes your ad copy, understands your offer, and responds to calls to action.

Life events: major events that cause emotional distress or financial difficulty. Bereavement, divorce, job loss, retirement (particularly unplanned), caring responsibilities, and relationship breakdown. Life event vulnerability is extremely common among people who seek financial advice — in fact, life events are one of the primary triggers for advice-seeking. This means a significant proportion of your inbound leads may be experiencing life event vulnerability at the point of contact.

Resilience: low ability to withstand financial or emotional shocks. This includes low or erratic income, over-indebtedness, low savings, and lack of financial safety net. Resilience vulnerability affects how someone perceives your marketing — someone in financial distress may be more susceptible to promises of quick solutions or may feel pressured by urgency language that a resilient person would simply ignore.

Capability: low knowledge or confidence in managing financial matters. This includes low financial literacy, low English language proficiency, low digital skills, and learning difficulties. Capability vulnerability is directly relevant to marketing because it affects whether someone understands your advertising, can navigate your website, can complete your forms, and can comprehend the implications of engaging with your firm.

The FCA is explicit that vulnerability is not a permanent label applied to a specific group of people. Anyone can become vulnerable at any time due to changes in health, circumstances, resilience, or capability. This means vulnerability isn't something you screen for at a point in time — it's something your marketing and processes should be designed to accommodate at all times.

For marketers, the practical implication is straightforward: design your campaigns, content, and processes assuming that a proportion of your audience is experiencing one or more vulnerability drivers right now. You don't need to know which individuals are vulnerable. You need systems and practices that treat everyone with care.

The words you use in advertising carry different weight depending on the emotional state of the person reading them. Copy that feels motivational to a confident, financially secure person can feel pressuring, frightening, or manipulative to someone in a vulnerable state.

Pressure and urgency language is the most common problem area. Phrases like "Act now before it's too late," "Don't miss your chance," "Limited availability," and "Time is running out" are standard marketing tools that create urgency. For someone experiencing anxiety, bereavement, or financial distress, these phrases can trigger panic-driven decisions. The FCA's guidance specifically flags urgency tactics as potentially harmful to vulnerable customers.

This doesn't mean you can never mention timing. "The tax year ends on 5 April, so reviewing your ISA position before then ensures you use your full allowance" is factual and helpful. "You're running out of time — act NOW or lose thousands" is pressuring and potentially misleading. The distinction is between informing and manipulating.

Fear-based messaging is common in financial services advertising. "Are you at risk of running out of money in retirement?" "Could your family be left with a huge inheritance tax bill?" These messages tap into genuine concerns, but for someone already experiencing anxiety about their finances, they amplify distress rather than offering a path to resolution. Reframe fear-based messages as empowerment messages: "Get clarity on whether your retirement plan is on track" rather than "Are you heading for a retirement crisis?"

Overpromising and guarantee language is both a compliance issue and a vulnerability concern. "We'll solve your financial worries" or "Peace of mind guaranteed" may technically violate advertising standards, but more importantly, they create expectations that vulnerable people may rely on. Someone in financial distress who is promised "peace of mind" may make commitments they can't afford based on that expectation.

Inclusive language means writing at a reading level that's accessible to people with varying capability levels. Financial services copy often defaults to jargon-heavy language: "amalgamation of legacy pension arrangements," "crystalisation events," "discretionary fund management." Plain English isn't just good marketing — it's a vulnerability accommodation. Write at a reading level that a stressed, distracted, or less financially literate person can understand clearly.

Tone should be warm, professional, and reassuring without being condescending. "We understand that thinking about your finances can feel overwhelming. We're here to help you understand your options clearly and at your own pace" is appropriate. "Don't worry — we'll take care of everything for you" is patronising and creates inappropriate dependency expectations.

Review your current ad copy, landing page content, and email templates through the lens of each vulnerability driver. For each piece of copy, ask: how would this read to someone who is bereaved? Anxious? In financial difficulty? Struggling with English? If the answer is "it might cause harm," revise it.

Your landing page is often the first substantive interaction a prospect has with your firm. For vulnerable customers, the design and accessibility of that page can determine whether they're able to understand your offer, navigate to the information they need, and engage on terms that protect them.

Web Content Accessibility Guidelines (WCAG) 2.1 Level AA should be your minimum standard. This isn't just about vulnerability — it's a legal requirement under the Equality Act 2010. But for vulnerable customers specifically, accessibility features serve as protective measures.

Readability: use a minimum body text size of 16px, clear sans-serif fonts, sufficient contrast ratios (minimum 4.5:1 for normal text), and adequate line spacing (1.5x). Avoid text embedded in images where it can't be resized. These aren't aesthetic preferences — they're functional requirements for people with visual impairments, cognitive difficulties, or who are reading on mobile in stressful situations.

Navigation clarity: your page should have a clear visual hierarchy, with the most important information (what you offer, what the next step is) immediately visible without scrolling. Complex multi-step forms, hidden navigation menus, and interstitial pop-ups create barriers for people with low digital skills or cognitive difficulties.

Form design: keep forms short and clearly labelled. Each field should have a visible label (not just placeholder text, which disappears when the user starts typing). Required fields should be clearly indicated. Error messages should explain what went wrong and how to fix it. For financial services specifically, avoid asking for sensitive information (income, assets, health status) in the initial contact form — this can feel invasive and may deter vulnerable people who are already cautious about sharing personal details.

Language alternatives: if your client base includes people with limited English proficiency, consider providing key information in simplified English or offering a phone number prominently for people who prefer verbal communication. For adviser firms operating in multicultural areas, this isn't optional — it's a practical accommodation for a real portion of your audience.

Exit routes: every page should make it easy for someone to leave without feeling trapped. Aggressive exit-intent pop-ups ("Wait! Don't leave without claiming your free guide!") are problematic for anyone, but particularly for vulnerable people who may feel manipulated by them. If someone wants to leave, let them leave.

Mobile responsiveness is a vulnerability consideration as well as a UX one. Many vulnerable people access the internet primarily through smartphones, and a significant proportion are on older or lower-specification devices. Ensure your pages load quickly and function correctly on a range of devices, not just the latest iPhone.

Consider adding a vulnerability-aware message to your contact page or form. Something like: "If you're going through a difficult time — such as bereavement, illness, or financial difficulty — please let us know. We can adjust our process to better support you." This signals to vulnerable prospects that your firm takes their circumstances seriously, and it gives them permission to disclose vulnerability early in the relationship.

The moment a lead arrives is where vulnerability obligations become most practical. How your team handles the first contact — the speed, the tone, the questions they ask — can either protect a vulnerable person or inadvertently cause harm.

First contact training is essential. Whoever answers enquiries — whether that's an administrator, a paraplanner, or the adviser themselves — needs to be able to recognise potential vulnerability indicators and respond appropriately. Training doesn't need to be extensive, but it should cover: what vulnerability looks like in conversation (distress, confusion, mention of bereavement or illness, difficulty understanding information, feeling rushed), how to slow down a conversation when vulnerability is detected, what to say ("I can hear this is a difficult time — there's no rush, and we can take this at whatever pace works for you"), and when to escalate to a senior person.

Scripted triage questions should include an open question that gives the prospect space to disclose relevant circumstances. "Can I ask what's prompted you to look into financial advice at this point?" is a natural conversation opener that often reveals life events, health concerns, or financial pressures without being intrusive. If someone responds with "My husband died three months ago and I don't know what to do about his pension," your team needs to know how to handle that conversation with empathy and appropriate signposting.

Pacing matters. The standard speed-to-lead guidance — contact within 15 minutes — remains valid, but the nature of the contact may need to adjust for vulnerability. A rapid callback to confirm receipt and schedule a proper conversation is appropriate. Launching into a sales qualification call with someone who is clearly distressed is not. The initial contact should establish trust and set expectations, not qualify budget and timeline.

Documentation is a regulatory requirement. If your team identifies potential vulnerability during the lead handling stage, it should be noted in your CRM with appropriate care (respecting data protection). This ensures the adviser who eventually meets the prospect is aware of the circumstances and can adjust their approach. It also creates the compliance record that demonstrates your firm took vulnerability into account at every stage of the customer journey.

Referral pathways: your team should know where to signpost people who need help beyond financial advice. Citizens Advice, StepChange (for debt), Samaritans (if someone expresses emotional distress), Cruse Bereavement Care, and the Money and Pensions Service are all relevant. Having these referral options readily available isn't just good practice — the FCA expects firms to signpost vulnerable customers to appropriate support.

Decline protocols: sometimes the right thing is to decline to act. If a prospect appears to be making a financial decision under extreme emotional distress, under undue influence from a third party, or without the capacity to understand what they're agreeing to, your firm should have a clear protocol for pausing the engagement. This protects both the prospect and the firm. Document the decision, explain it to the prospect with care, and suggest they return when their circumstances allow for clearer decision-making.

The Consumer Duty, effective since July 2023, introduced four outcomes that firms must deliver: products and services, price and value, consumer understanding, and consumer support. All four intersect with marketing, and for vulnerable customers the intersections are sharper.

Consumer understanding is the most directly relevant outcome for marketing. The Duty requires firms to ensure their communications are likely to be understood by the customers in their target market, including those who may have characteristics of vulnerability. This isn't a generic requirement — it's specific to your actual target market. If you market pension consolidation services, your communications must be understandable to the kinds of people who have multiple pension pots, including those who may have low financial literacy or who may be going through life events that affect their capacity to process complex information.

Practically, this means testing your marketing communications with real people who represent your target market, not just your compliance team. If your landing page copy requires a financial planning qualification to understand, it fails the Consumer Duty consumer understanding test regardless of how accurately it describes your service.

Consumer support requires that firms don't create unreasonable barriers to customers. In a marketing context, this means your contact processes should be accessible, your response times should be reasonable, and your follow-up should be supportive rather than aggressive. A lead nurture sequence that sends six emails in a week to someone who didn't respond to the first one is a support failure, not a marketing success. For vulnerable customers, aggressive follow-up can cause genuine distress.

Price and value intersects with marketing where your communications set expectations about costs. If your advertising says "free initial consultation" but the meeting is a high-pressure sales pitch that leaves the prospect feeling obligated, you've created a value gap. Consumer Duty requires that the value proposition in your marketing matches the actual experience.

Products and services is relevant where your marketing directs different customers toward different offerings. If your marketing algorithm automatically channels vulnerable or lower-value prospects toward a different (inferior) service pathway than wealthier prospects, that's a potential Consumer Duty issue.

The crossover between vulnerability guidance and Consumer Duty creates a reinforcing framework: vulnerability obligations tell you to consider individual circumstances; Consumer Duty tells you to ensure good outcomes. For marketing, the combined requirement is that your campaigns should be truthful, accessible, non-pressuring, and designed with the understanding that some of the people who respond will be in difficult circumstances. Firms that approach marketing with this mindset rarely have compliance problems — and they tend to attract better clients, because thoughtful marketing attracts thoughtful people.

For a broader view of how Consumer Duty affects marketing practices, see our Consumer Duty year three analysis.

Some marketing practices that are common in financial services create specific risks when viewed through the vulnerability lens. This isn't an exhaustive list, but these are the patterns we see most frequently in adviser firm campaigns that could expose the firm to regulatory challenge.

Countdown timers and artificial scarcity: "Only 3 consultation slots remaining this week!" or countdown timers on landing pages create artificial pressure that can drive vulnerable people into premature decisions. If you genuinely have limited availability, state it factually without urgency framing.

Before-and-after framing: "Sarah was worried about her pension. Now she's retired comfortably with our help." This format implies guaranteed outcomes and creates expectations that may not be met. Testimonials are valuable, but they should describe the experience of working with you, not imply specific financial results. The FCA's COBS 4.6 is clear on this point.

Fear-amplification sequences: email sequences that progressively escalate fear ("Are you sure your pension is safe?" followed by "Three things that could destroy your retirement" followed by "Last chance to protect your future"). These are designed to create anxiety that drives action, which is inherently harmful for vulnerable people experiencing existing anxiety or distress.

Clickbait-style targeting: ads designed to generate curiosity clicks rather than informed responses. "The one mistake that's costing you thousands in retirement" gets clicks, but it attracts a wide audience including people who are financially anxious and may not need your services at all. Targeted, specific ads attract appropriate prospects; clickbait attracts everyone, including the most vulnerable.

Invasive retargeting: following someone around the internet with pension ads for 90 days after they visited your site once can feel stalker-like to anyone, but for someone in a vulnerable state it can feel genuinely oppressive. Set reasonable frequency caps (3-5 impressions per week maximum) and limit retargeting windows (30 days is usually sufficient).

Automatic qualification escalation: some lead management systems automatically escalate follow-up intensity when a prospect doesn't respond. Three emails, then a phone call, then a text message, then another email. For someone who has decided not to proceed — or who submitted the form during a moment of distress and regretted it — this escalation is harmful. Implement reasonable contact limits and make it easy for someone to opt out at any stage.

Unsolicited advice in marketing materials: providing specific financial recommendations in your advertising ("You should transfer your pension before April") crosses the line from marketing into advice and could cause vulnerable people to act on a generic recommendation that's inappropriate for their specific circumstances.

The principle underlying all of these: your marketing should attract and inform, not pressure and manipulate. This is not just a vulnerability requirement — it's a Consumer Duty requirement, an FCA financial promotions requirement, and, frankly, the standard of any firm that wants to build a sustainable practice based on trust rather than tactics.

Use this checklist to review your current marketing campaigns against vulnerability requirements. This isn't a compliance sign-off — it's a practical tool to identify areas that may need attention.

Ad copy review: read every active ad through the lens of each vulnerability driver. Does any copy use fear, urgency, or pressure language? Would the message be clear to someone with low financial literacy? Could the ad mislead someone in financial distress about what to expect?

Landing page accessibility: test your key landing pages against WCAG 2.1 AA standards. Check text size, contrast ratios, form labelling, error handling, and mobile responsiveness. Use an accessibility testing tool (WAVE, axe, or Lighthouse) for an automated initial check, then review manually for readability and clarity.

Form design: review your lead capture forms. Are they asking for the minimum information needed? Are fields clearly labelled? Is there an accessible alternative (phone number, email) for people who struggle with forms? Are you asking sensitive questions (income, health) at an inappropriate early stage?

Email sequences: map your entire nurture sequence. How many emails does someone receive if they don't respond? Is there an easy, visible unsubscribe in every email? Does the sequence escalate in pressure over time? Would someone in distress find the frequency and tone supportive or oppressive?

First contact process: document exactly what happens when a lead arrives. Who responds? How quickly? What do they say? Is there training on vulnerability recognition? Is there a script or guideline for slowing down the conversation when vulnerability is detected? Are referral pathways (Citizens Advice, StepChange, etc.) documented and accessible?

Retargeting configuration: check your retargeting audience windows and frequency caps. Are you following people for longer than 30 days? Are you showing more than 3-5 impressions per week? Is there a process to remove converted leads from retargeting audiences?

Compliance review integration: is vulnerability considered as part of your financial promotion approval process? When your compliance reviewer signs off on an ad or landing page, are they assessing it against vulnerability criteria or only against standard FCA financial promotion rules?

Documentation and record-keeping: are you maintaining records of your vulnerability considerations in marketing decisions? If the FCA asked you to demonstrate how you consider vulnerability in your marketing practices, could you show them?

Staff training records: when was vulnerability training last delivered to your marketing team and lead handling staff? Is it part of your ongoing training programme or a one-off exercise?

This audit should be repeated at least annually, and whenever you launch a significant new campaign or change your lead handling process. Vulnerability obligations aren't a one-time checkbox — they're an ongoing commitment that should be embedded in how your firm approaches marketing at every level. The firms that get this right don't just avoid regulatory problems — they build deeper trust with every prospect they interact with, which translates directly into better client relationships and stronger long-term growth.

For the broader context on how vulnerability data relates to the UK advice market, see our industry statistics. For how Consumer Duty shapes these obligations, see our Consumer Duty analysis.