According to the study by IP Integration (IPI), 98% of surveyed UK retail and financial services businesses say they are prepared for the Financial Conduct Authority’s (FCA) increasing scrutiny of how they treat vulnerable customers. The results suggest, however, that the systems used to automatically capture and retrieve records of those interactions have not kept up. As a result, many organisations would need days instead of hours to show a regulator how an individual vulnerable customer was supported.
The research was conducted by Cavell, a member of the Market Research Society (MRS), among 400 compliance, operations, and customer operations leaders. Fieldwork took place between 20 May and 1 June 2026, following MRS and ESOMAR research standards.
Regulatory pressure and board-level attention
Under the Consumer Duty, the FCA expects firms to demonstrate good outcomes for vulnerable customers, and being able to evidence the treatment of individual customers is central to meeting that standard. Rules for buy now, pay later (BNPL) introduced in July 2026 extend those expectations to a payment method that 99.5% of surveyed businesses currently offer.
The survey shows that the topic has reached senior governance. 94% of respondents say vulnerable customer readiness has been talked over at board level in the past six months, and 99% have tested their processes against a mock regulatory audit within the past year. Confidence varies by function, though. 90% of compliance leaders say they could quickly present evidence of a vulnerable customer interaction, compared with 99% of operations leaders.
Collecting evidence lags behind policy
Only 25% of businesses have vulnerable customer interactions logged automatically and in a searchable format. Elsewhere, records are logged manually by staff (27%), spread across multiple systems (25%), or captured inconsistently (23%). The numbers show that teams may have to locate and assemble a customer’s record by hand before sharing it with a regulator. 63% of respondents say this would take three working days or more for a single interaction, while 4% could complete it on the same day.
Identification of vulnerability is also largely manual. A third (33%) of businesses report that frontline employees mainly rely on their judgement and training to recognise vulnerable customers during live conversations.
BNPL adds touchpoints to the record
Since July 2026, regulated BNPL lenders have been required to assess affordability, support customers who fall into difficulty, and demonstrate that they have done so. A single BNPL journey can span checkout, affordability checks, customer service, and complaints, increasing the number of touchpoints that must be captured and linked into one record. Before the rules took effect, 94% of businesses said they could quickly evidence a BNPL affordability or vulnerability decision. With the rules now in force, the emphasis moves from stated confidence to execution across every stage of that journey.
Commenting on the findings, Annabelle Goymer, Head of Customer Success at IPI, noted that circumstances such as bereavement, health problems, or a sudden loss of income can make anyone vulnerable, and pointed to FCA research indicating that only four in ten people inform their provider when this happens. According to Goymer, firms therefore need to recognise the signs rather than wait for customers to disclose them, supported by prompts within existing frontline systems and automatic capture of interactions during conversations instead of notes written afterwards. The official added that regulators are ultimately looking for evidence of good outcomes, namely that the customer was understood and appropriately supported.
Founded in 2001, UK-based IPI combines contact centre consultancy with its own technology and works with organisations across financial services, insurance, retail, utilities, travel, higher education, and the public sector.
