WFM guideFCA regulated — not legal advice

Handling vulnerable customers in contact centres

Q: Who is a vulnerable customer under FCA rules?

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 FCA identifies four drivers of vulnerability: (1) Health — physical or mental health conditions, disability, addiction, bereavement. (2) Life events — retirement, divorce, job loss, becoming a carer. (3) Resilience — low emotional or financial resilience, low ability to cope with financial shock. (4) Capability — low financial literacy, low digital literacy, English as an additional language. Vulnerability is often temporary, situational, and not visibly apparent. The FCA estimates that approximately 47% of UK adults show at least one characteristic of vulnerability.

Q: What does Consumer Duty require of contact centres?

FCA Consumer Duty (effective July 2023 for new business, July 2024 for closed book) requires firms to deliver good outcomes for retail customers, including those in vulnerable circumstances. For contact centres, this means: (1) Agents must be able to identify vulnerability signals during a call and act on them appropriately. (2) The firm must have processes to flag and record vulnerability so that subsequent contacts are handled with appropriate care. (3) Products and services must be designed to be accessible and not systematically disadvantage vulnerable groups. (4) The firm must monitor and evidence that vulnerable customers are receiving outcomes equivalent to non-vulnerable customers. Consumer Duty is not just a policy document — it requires operational evidence, which means contact centre monitoring, QA scoring, and complaints data must specifically track vulnerable customer outcomes.

Q: How does vulnerable customer handling affect contact centre AHT?

Contacts with identified vulnerable customers typically have 40–100% higher AHT than standard contacts. The additional time comes from: extended empathy and de-escalation (2–5 additional minutes), additional checks before proceeding (verifying the customer understands the transaction, offering a call-back if distressed), adaptation of communication (simpler language, slower pace, reading information aloud), vulnerability flagging and recording in the CRM (2–4 additional ACW minutes). If 5% of inbound contacts are identified as vulnerable with 15-min AHT vs. 7-min standard AHT, blended AHT is 7.4 min — not 7 min. At high vulnerable-contact proportions (financial hardship teams, bereavement teams), vulnerability AHT uplift must be modelled as a separate Erlang C input.

Vulnerable customer handling is both a regulatory obligation and a WFM planning input. FCA Consumer Duty (effective July 2023) requires firms to evidence good outcomes for vulnerable customers — not just to have a policy. Contact centres must train agents to identify vulnerability, adapt their handling, and document the outcome. Each of these takes time: time that must be in the AHT model.

Note on regulatory requirements

This guide describes FCA and related regulatory requirements as they apply to regulated contact centres in Great Britain. Regulatory obligations vary by authorisation type, business model, and sector. Always verify the requirements applicable to your firm with your compliance team or legal counsel before changing regulated processes. This guide is for operational context, not legal advice.

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The FCA vulnerability framework

FCA definition (Guidance FG21/1)

“A vulnerable consumer is 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 FCA estimates that approximately 47% of UK adults show at least one characteristic of potential vulnerability. Vulnerability is often temporary, situational, and not visibly apparent from a customer file — which is why agents must be trained to identify signals in real time.

Consumer Duty came into force July 2023 (new business) and July 2024 (closed book). It extends and strengthens the vulnerability framework — firms must now evidence outcomes, not just process.

The four vulnerability drivers

🏥

Health

Physical illness, disability, mental health conditions, cognitive impairment, addiction, bereavement

Contact signals

→Difficulty following conversation structure
→Emotional distress (crying, agitation)
→Confusion about product or process
→Mention of illness, medication, carer

Agent response

Slow pace, simpler language, offer call-back, do not pressure for decisions during the call. Flag on CRM.

📅

Life events

Retirement, divorce/separation, domestic abuse, job loss, becoming a primary carer, bereavement

Contact signals

→Account holder recently deceased (caller is next of kin)
→Mention of separation or divorce affecting finances
→Customer has recently retired and queries changed income
→Caller expresses financial distress linked to life change

Agent response

Acknowledge the life event, do not rush, signpost to specialist support or bereavement team. Extended ACW to document.

⚡

Resilience

Low ability to cope with financial or emotional shock; over-indebtedness; low financial stability

Contact signals

→Customer mentions difficulty paying bills
→Multiple recent bounced payments
→Customer describes financial panic
→Requests for payment deferrals or hardship programmes

Agent response

Do not escalate charges during the call. Refer to financial hardship team or specialist. Document vulnerability flag.

📖

Capability

Low financial literacy, low digital literacy, English as an additional language, learning disability

Contact signals

→Difficulty understanding product terms despite explanation
→Customer asks to have information repeated multiple times
→Language barrier indicators
→Customer appears to have been directed by a third party

Agent response

Use plain language, no jargon, offer written follow-up, check understanding repeatedly. Third-party carer verification if relevant.

Consumer Duty obligations for contact centres

Agent identification and intervention

All agents in customer-facing roles must be trained to identify the four vulnerability drivers during a call. Training must include: signals to listen for, how to adapt communication, when and how to escalate. Consumer Duty requires that this is not just policy — it must be evidenced through QA assessments that specifically evaluate vulnerability handling.

Evidenced by

QA scoring framework with vulnerability criteria; agent training records; pass rates on vulnerability e-learning

Vulnerability recording and flagging

When vulnerability is identified, it must be recorded on the customer's account so that subsequent contacts (by any channel) are handled with appropriate care. This requires a CRM flag or note that is visible to all agents. The flag must be reversible — vulnerability is not a permanent status.

Evidenced by

CRM vulnerability flag field; record of flags applied and removed; % of contacts where vulnerability was identified and flagged

Outcome monitoring

Consumer Duty requires firms to monitor and evidence that vulnerable customers receive outcomes equivalent to non-vulnerable customers. For contact centres, this means: comparing complaint rates, FCR, and CSAT scores between vulnerable-flagged and standard contacts. Where gaps exist, the firm must be able to demonstrate what actions it took to close them.

Evidenced by

MI report comparing vulnerable vs. standard customer outcomes; complaints data segmented by vulnerability flag; remediation actions documented

Accessible products and processes

The contact centre must have accessible alternatives for customers who cannot use the standard channel — for example, extended call handling time for customers with communication difficulties, relay services for deaf customers, large-print confirmation letters. The AHT uplift for these adaptations must be in the staffing model.

Evidenced by

Accessibility policy; relay service access log; extended AHT accommodation in Erlang C inputs

AHT uplift: vulnerable contacts vs. standard contacts

AHT component breakdown (financial services inbound voice, illustrative)

Standard contact

ID verification	1–2 min
Reason for contact	1–2 min
Resolution	3–5 min
Standard ACW	1–2 min
Total AHT	6–11 min

Vulnerable customer contact (additional time)

Standard phases above	6–11 min
Empathy, acknowledgement, adaptation	+2–5 min
Understanding checks and re-explanation	+2–4 min
Vulnerability flag and extended ACW	+2–4 min
Escalation to specialist (if required)	+3–8 min
Total AHT	15–32 min

WFM implication: At 5% vulnerable-flagged contacts with 20-min AHT vs. 8-min standard, blended AHT is (0.95 × 8) + (0.05 × 20) = 8.6 min. This 7.5% AHT inflation translates to approximately 7% more Erlang C minimum agents for the same service level. If your AHT input is 8 min, you are systematically underestimating required headcount by that margin. Financial hardship teams and bereavement teams — where vulnerable-contact proportions reach 70–100% — must use vulnerability-adjusted AHT as the Erlang C input, not standard AHT.

Vulnerable customer questions

Who is a vulnerable customer under FCA rules?

Someone who, due to personal circumstances, is especially susceptible to harm — particularly when a firm is not acting with appropriate care. FCA identifies four drivers: health (illness, disability, mental health), life events (bereavement, job loss, retirement), resilience (low financial/emotional stability), and capability (low financial literacy, language barriers). The FCA estimates 47% of UK adults show at least one vulnerability characteristic.

What does Consumer Duty require of contact centres?

FCA Consumer Duty (effective July 2023) requires firms to evidence good outcomes for vulnerable customers. Contact centres must: train agents to identify the four vulnerability drivers; record vulnerability flags on customer accounts visible to all agents; monitor and evidence that vulnerable customers receive equivalent outcomes; and provide accessible alternatives for customers who cannot use standard channels.

How does vulnerable customer handling affect contact centre AHT?

Vulnerable contacts typically run 40–100% higher AHT than standard contacts — typically 15–32 min vs. 6–11 min in financial services. Additional time comes from empathy and de-escalation, understanding checks, extended ACW for vulnerability documentation, and sometimes specialist escalation. At 5% vulnerable proportion, blended AHT is ~8.6 min vs. 8 min standard — a 7.5% uplift that must be in the Erlang C input.