Firms risk missing commercial value by treating vulnerability as solely a compliance issue, warns MorganAsh
21 September 2026
Financial services firms risk missing significant commercial opportunities by treating customer vulnerability primarily as a regulatory requirement, according to support services provider MorganAsh.
The introduction of Consumer Duty in 2023 increased emphasis on identifying and responding to customers in vulnerable circumstances. While some firms may view this as additional overhead or oversight, MorganAsh urges firms to consider that there is significant commercial value in understanding more about their customers’ characteristics of vulnerability.
The support services provider argues that better customer insights can help firms make more informed decisions, improve personalisation of products and services, and engage with customers before their circumstances deteriorate.
The potential prize extends far beyond avoiding regulatory action. The latest data from the Money Advice Trust, cited by MorganAsh, puts the annual household spending power of the UK’s 16 million disabled people at £446 billion, while 75% of disabled consumers believe businesses are losing out due to poor accessibility. There are real commercial gains possible from simply knowing more about vulnerable customers, personalising their experience, creating targeted products and simply responding to their personal characteristics.
Andrew Gething, managing director of MorganAsh, said:
“We’ve long said that the focus of Consumer Duty and customer vulnerability should be on the carrot and not just the stick. All too often the narrative is around what happens if you don’t, rather than the considerable business benefits of why you should.
“Of course, firms do need to meet the requirements of Consumer Duty, but that is only one part of the picture. There are significant commercial opportunities and clear competitive advantages in understanding customers properly – and using your insights to make better decisions. Whether that means avoiding an unnecessary decline and pivoting to a different product, retaining a customer who might otherwise leave or identifying a need for a new product, better vulnerability data can give firms a much clearer picture of the people they are serving and create real opportunities for greater personalisation.”
Figures from McKinsey have put the potential revenue uplift from personalisation at around 40%, while other research has found that poor personalisation is a significant driver of customers switching providers.
The potential benefits of good vulnerable customer management extend across financial services and other regulated sectors, with MorganAsh highlighting applications across debt and credit, insurance, utilities and wealth management.
The support services provider will highlight the commercial impact of this approach through a live case study on an upcoming industry webinar, where one firm’s experience will demonstrate how vulnerability assessment contributed to fewer automatic declines, more approvals and the development of a brand-new product.
The webinar will also look at recent FCA enforcement activity and what firms can learn from it, alongside the revenue opportunities hiding in better data and the case for digital vulnerability management across different sectors. The session will also consider the potential for sharing structured vulnerability data, reducing the need for clients to repeatedly explain their circumstances.
Andrew adds: “Through the combination of technology being readily available and fantastic guidance – particularly from the likes of the Chartered Insurance Institute (CII), customer vulnerability management doesn’t need to be the burden that firms think it is.
“If a firm can proactively identify a customer’s circumstances, understand them properly and use that information appropriately, they have the ability to improve customer outcomes, while making better commercial decisions too. That is a far more valuable proposition than viewing vulnerability as just a compliance cost.”
MorganAsh is a specialist in Consumer Duty and customer vulnerability. The firm provides its multi-award-winning MorganAsh Resilience System (MARS) to help firms understand and monitor vulnerable customers and deliver good outcomes – as required by Consumer Duty. It is in use across financial services and the utilities sector, enabling businesses to adopt a consistent approach to identifying vulnerable characteristics and generate an objective Resilience Rating – much like a credit score.
To register for the webinar, please click here. To find out more about MARS or access a free trial, visit: morganash.com/mars or phone: 0330 159 8162.
