How are key sectors performing against FCA vulnerability benchmarks?

Around half of all customers have characteristics of vulnerability.

Related topics:  Regulation,  Vulnerability
Rozi Jones | Editor, Financial Reporter
27th May 2026
FCA

New data from the MorganAsh Resilience System (MARS) reveals how key sectors are performing against FCA benchmarks for vulnerable customers, with firms using digital customer vulnerability management reporting a higher proportion of vulnerable customers than those using initial manual methods.

Based on three years of vulnerable customer data, the findings from MorganAsh show that the mean proportion of vulnerable customers across its MARS digital vulnerability management platform is 50% - in line with the FCA’s established benchmark.

Breaking down the data, mortgage firms using MARS report that 36% of their customers are vulnerable, while advice firms report 42%. Mortgage firms report a smaller proportion of very vulnerable customers – at 13% – compared to 22% for advice firms. The higher proportion reported by advice firms is largely linked to differences in customer age profiles across the two sectors.

Meanwhile, the insurance sector – whose customer base more closely reflects the general population – reports 48% of customers in vulnerable circumstances.

The sector with the highest proportion is unsurprisingly the debt sector with 99% of customers in vulnerable circumstances, even excluding financial vulnerability measures. MorganAsh explains that it is high-scoring sectors such as this that contribute to the 50% proportion of vulnerable customers recorded by MARS.

MorganAsh recommends that while the 50% headline figure from the Financial Lives Survey is useful, it is better to benchmark by age and sector when comparing with peers. 

Andrew Gething, managing director of MorganAsh, said: “With most firms reporting a proportion of vulnerable customers close to the FCA’s benchmarks, it really calls into question those firms that still say they have few to no vulnerable customers. In reality, what they have is a significant data problem – they don’t have the robust data required to know who their vulnerable customers are, let alone what challenges those customers face and the outcomes they receive. Given the clear requirements set out under Consumer Duty to identify, monitor, support and report on customer vulnerability, this a clear issue. More recently, the FCA has requested firms consider the impact of the Iran war and hence, firms need extensive data to be able to assess these scenarios.

“While firms will have different proportions of vulnerable customers based on their sector, it’s still important to benchmark ourselves against other sectors and established data points like the FCA’s Financial Lives Survey. The findings are a great example of the advancements we’re seeing in digital customer vulnerability management, helping firms to improve accuracy and bring real efficiencies to understanding, monitoring and reporting on customer vulnerability. With the right foundations in place, there is the opportunity to unlock the competitive advantage and commercial benefits of being closer to clients, improving and personalising products and services.” 

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