Vulnerable client management is an opportunity for advice firms to grow, rather than a cost, the Chartered Insurance Institute (CII) has said.
The professional body has today (7 April, 2026) released its latest ‘Road to Consumer Trust' report, which it said sets a "proportionate, practical approach" to vulnerability management and outcomes monitoring.
The CII Consumer Duty, Proportionality and Vulnerability Management for Financial Planning Firms Roundtable summary report shared the findings of regulatory specialists, financial planning leaders, compliance experts, and vulnerability practitioners.
The report found that effective vulnerability management can support firms in expanding their potential client base, reducing the cost of ad hoc vulnerability handling, evidencing value to clients and regulators, and building long-term consumer trust.
With demonstration of how firms are delivering good customer outcomes identified as a key supervisory priority for the Financial Conduct Authority in 2026, roundtable participants included in the report outlined four core principles for determining the right proportional level of Consumer Duty implementation and vulnerability management.
The principles included the size of firm; role in distribution chain; characteristics of client base; and risk level of product or service.
Firms urged to measure same outcomes for vulnerable and non-vulnerable clients
The report concluded that firms should measure the same outcomes for vulnerable and non-vulnerable clients, and track the additional support provided to achieve those outcomes.
Evidence of good outcomes throughout the journey, not just at the endpoint, and building robust vulnerability data infrastructure were recognised in the CII's report as "essential prerequisites" for meaningful outcomes comparison.
The report also outlined three key indicators of when firms may not be doing enough to effectively manage vulnerability.
These included a ‘one-size-fits-all' vulnerability process, cultural resistance, and opaque outcomes monitoring systems that cannot identify whether different client groups are receiving good outcomes.
Recommendations set out in the report involved building strong data foundations, embedding inclusive design, and addressing cultural fears around vulnerability.
CII CEO Matthew Hill said: "Vulnerability management is often viewed as a regulatory burden or an added cost, while it is in fact an opportunity for firms to strengthen client relationships, demonstrate tangible value, and build lasting trust.
"By adapting a proportionate and practical approach, as outlined in the report, firms can not only meet regulatory expectations but also broaden their reach, improve efficiency, and deliver consistently better outcomes for all customers."
The CII's report findings come after it launched a guide to help firms serve clients in vulnerable circumstances at the end of last year.
