FCA protection study: Vulnerability assessments could transform how protection needs are identified, MorganAsh

22 September 2026

Andrew Gething, managing director of MorganAsh, said:

“The FCA’s final report makes clear that closing the protection gap is not simply about getting more people to buy protection. It is about making sure people can recognise when protection is relevant to their circumstances, understand their options and access cover that meets their needs.

“This is particularly important for customers with characteristics of vulnerability, who may already be less financial resilient or face additional barriers to accessing protection. The FCA rightly identifies complex sales processes, lengthy underwriting, unclear communications and limited availability as significant barriers. It’s an important reminder that we have to consider customers being vulnerable long before the point of claim.

“The focus on prompts, clearer communications and improved access is welcome, but there is an opportunity to go further by making support more responsive to the individual. Protection needs can change as a customer’s health, finances or circumstances change, and firms need to recognise those moments proactively and respond accordingly.

“For years, we have identified life events such as marriage, children or mortgages as triggers to consider protection needs. The advent of vulnerability assessments covering all life events provides a far more nuanced and detailed understanding of consumer risks and protection needs. With vulnerability assessments becoming increasingly embedded across financial services and utilities, there is a greater opportunity to engage on protection.

“The real test will be whether firms can translate these principles into consistently better outcomes. That means having the data and insight to understand who is engaging, where vulnerable customers are encountering barriers and whether the support being provided is actually making a difference.

“The fundamental point is that information being available is not the same as a customer being able to understand it, act on it and access the protection they need. A more personalised approach, informed by good data and clear understanding of customer circumstances, can help close that gap.”