While four in five brokers report encountering vulnerable clients, more than half of lenders said they have not received a single disclosure in the past 12 months, according to new research from Smart Money People.
As a result, only 58.1% of brokers think the industry has made progress in supporting client vulnerability. Encouragingly, more brokers now say they disclose “most” or “all” cases to lenders compared with 2024. But almost a third say they don’t disclose any cases at all.
The research includes nearly 600 responses from brokers and lenders. In 2025, more than four in five brokers reported encountering vulnerable clients, broadly consistent with 2024. Encouragingly, the proportion of brokers disclosing “more than half” of identified vulnerabilities to lenders has increased, although 30.9% of brokers still report disclosing none.
Despite this, over half of lenders said they’d not received a single disclosure in the past 12 months. While internal recording practices may partly explain this, it suggests a significant volume of broker-identified vulnerabilities is still not reaching lenders.
Both groups reported high confidence in identifying and responding to vulnerable customers. However, awareness of FCA vulnerability drivers is not universal, especially among lenders.
Brokers mainly see process failures such as unclear routes or inconsistent systems as the main obstacles to disclosure, while lenders point to client factors like reluctance to disclose or fear of negative impact. This highlights the need for clearer communication and shared accountability.
Brokers seek simple, practical tools such as clear guides, integrated disclosure points in applications, and reassurance on non-discrimination. Meanwhile, lenders prioritise dedicated online areas, expert input, and training. Both groups see value in more structured guidance, but their priorities differ.
Jess Trueman, head of business development at Smart Money People, said: “This year’s research shows a market moving in the right direction but still held back by structural and cultural barriers that prevent consistent vulnerability disclosure.
“Brokers are confident in their understanding of vulnerability and most encounter it regularly in their client base. Encouragingly, more brokers now say they disclose “most” or “all” cases to lenders compared with 2024. But almost a third still disclose none – a reminder that awareness does not always translate into action.
“Lenders report high confidence in their ability to act on disclosures but admit they receive them only rarely. More than half said they had not received a single disclosure in the past year, a stark contrast to brokers’ claims of increasing disclosure. This disconnect exposes weaknesses in the routes, systems, and consistency of communication between intermediaries and lenders.
“The overall conclusion is clear: the knowledge is there, the willingness is there, but the infrastructure to support consistent disclosure is still not fit for purpose.”
