The FCA’s Drivers of Vulnerability Are Your Enquiry List

Read the FCA’s four drivers of vulnerability and then read your own enquiry list. Bereavement, redundancy, relationship breakdown, a health diagnosis, retirement — the drivers are not an edge case for an advice firm. They are the reasons people ring one. And the website is what meets them first.

This is a practical account of what the FCA’s vulnerability guidance expects of communications and digital journeys, and what that means for the design of an adviser’s website. It is the companion to your website is a financial promotion, which covered what the site may say. Central Systems is not authorised by the FCA and this is not compliance advice — your firm decides how the guidance applies to it.

Who the guidance is actually about

FG21/1 defines vulnerability broadly, and explicitly as a spectrum rather than a category:

The four drivers are set out at 2.6: health (“health conditions or illnesses that affect ability to carry out day-to-day tasks”), life events (“such as bereavement, job loss or relationship breakdown”), resilience (“low ability to withstand financial or emotional shocks”) and capability — which includes “low knowledge of financial matters or low confidence in managing money” and, pointedly for a website, “low capability in other relevant areas such as literacy, or digital skills”.

Put that beside a typical adviser’s new-client sources and the overlap is close to total. A firm whose website works well only for a confident, healthy, unhurried reader has designed for the minority of its own market.

What the guidance says about communications

FG21/1 asks firms to “ensure all communications and information about products and services are presented in ways that are understandable for these consumers”, and to “consider how they communicate with vulnerable consumers… Where possible, firms should offer multiple channels so vulnerable consumers have a choice.”

That duty runs across the whole relationship. Paragraph 4.65 lists marketing, point of sale, post-contractual information, information about changes, and complaints processes. Marketing is in that list, which means the public website is in scope, not just the client portal.

Paragraph 4.66 asks firms to consider these needs “when designing communications”, and 4.67 to provide different formats where proportionate, “particularly for key documents”. The examples the FCA gives of putting this into practice include large print, “colour schemes friendly to people with conditions such as dyslexia”, audio options, simplified versions using infographics — and, in as many words, “accessible websites”.

Paragraph 4.69 adds that firms “should consider the requirements of the Equality Act 2010”, and earlier, at 4.42, the guidance draws the parallel with “the anticipatory duty under the Equality Act that requires reasonable adjustments for people with disabilities”. Anticipatory is the operative word: the adjustment is expected before a particular person needs it, which is a design brief rather than a support policy.

The paragraph that governs online journeys

For any firm with a booking tool, a planning calculator or a multi-step enquiry form, 4.43 is the one to read:

An exit lane and a visible phone number are not conversion leaks. In this guidance they are the expected design of an online journey — and for an audience arriving mid-crisis, the firm that offers a way out of the form is the one that gets the call.

What that means for the build

• A phone route on every step, not only on the contact page. Somebody stuck at question four should not have to go looking.
• No timers, no countdowns, no artificial urgency. “More time” is in the guidance; pressure tactics work against it.
• Let people stop and come back. Long forms should hold what has been entered, or be short enough that losing it does not matter.
• Design for a reader who is not at their best. Generous text size, strong contrast, large tap targets, clear focus states, properly labelled fields, full keyboard operation. This is ordinary accessibility work; the guidance simply makes it a professional expectation rather than a preference.
• Plain language, and short sentences, in the places that matter — the first meeting, fees, what happens next, how to complain.
• Offer the alternative formats for key documents rather than treating a PDF as the only version.
• Signpost away where that is the honest answer. Pension Wise and MoneyHelper exist, and pointing to them costs an enquiry you did not want.
• Test it with real people, which the Consumer Duty already expects of communications — see the financial promotion post.

Our financial advisers page covers the wider site: structuring around situations rather than products, qualified enquiry routes, planning tools, and what a rebuild involves.

What we would not build for an advice firm

• A form with no way out. No phone number, no save, no “speak to someone instead”.
• Countdown timers or scarcity messaging on an advice service.
• Grey 11px small print carrying the information that matters most.
• A chat widget as the only support route, on a site whose audience includes people with low digital confidence.
• Interfaces that only work with a mouse, or that depend on hover to reveal anything meaningful.
• Vulnerability wording we drafted. What your firm does for clients in vulnerable circumstances is your policy, published as you approve it.

Sources and method

• FCA FG21/1, Guidance for firms on the fair treatment of vulnerable customers — paragraphs 2.5 and 2.6 (definition and the four drivers), 4.42 (the Equality Act parallel), 4.43 (self-service flexibility and the exit lane), 4.64 to 4.69 (communications, formats, the practical examples including accessible websites, and the Equality Act).
• FCA, the guidance’s landing page.

What this post does not do. Central Systems is not authorised or regulated by the FCA, and this is not legal, regulatory or compliance advice. It does not tell any firm what its vulnerability policy should contain, how to identify or record a client’s circumstances, or how to train staff — FG21/1 covers all of that and much of it has nothing to do with a website. It does not restate the Consumer Duty, the Equality Act, or accessibility standards in full. Guidance is revised; the linked source is authoritative and this page is not.

Questions advice firms ask us

Is this not just accessibility by another name?

Accessibility is most of the website answer, and it is the part that is well understood and testable. The guidance is broader: it also covers life events and capability, which show up as pacing, plain language and a way to reach a person — things an accessibility audit will not flag.

Does a visible phone number not reduce online conversions?

It moves them to the phone, which for this audience is frequently the better conversation. The guidance contemplates exactly that, and a first meeting booked by phone is worth as much as one booked by form.

Do we need a vulnerability statement on the website?

Many firms publish one and it can be reassuring, but it is your firm’s policy and wording. Publishing a statement is not a substitute for the site itself being usable.

Our clients are mostly high-net-worth. Does this apply?

The guidance says all customers are at risk of becoming vulnerable, and the drivers include bereavement and health. Wealth is not a shield against either, and much of what brings a wealthy client to an adviser is on the list.

What about the planning tools?

Same principles: no pressure, an obvious way to stop, a route to a person, and output a reader can follow. The rules about what those tools may say are in the companion post.

How do we know if our site is any good at this?

Have somebody who is not in the industry, and ideally not a confident web user, try to book a first meeting while you watch. It takes an afternoon and finds more than a checklist does.