The Equity Release Council, in collaboration with Inclusive Outcomes, has published a sector specific review of approaches to vulnerability in later life lending. The report recognises the strong foundations already in place and offers practical tools to help firms build on this work and embed consistent good outcomes across the market.
Titled 'Later Life Lending and Customer Vulnerability', the report brings together examples of good practice, real-life case studies, and strategic priorities to help firms navigate complex situations with confidence. It encourages the sector to continue raising the bar by integrating vulnerability considerations into advice, product design, and customer service – recognising the importance of doing so given the age profile of customers and the potential for cognitive decline in later life.
Key areas of good practice already being delivered across the market include:
• Structured identification of customers in vulnerable circumstances and data capture: The integration of vulnerability questions into fact-find processes to ensure early detection and tailored support, as well as upskilling teams to identify vulnerability.
• Dedicated adviser and staff training: With firms combining annual e-learning, real-time coaching, and role-specific training to build confidence and capacity.
• Use of vulnerability champions: Front-line advocates supporting colleagues, sharing learning, and surfacing insights to inform broader policy and process improvements.
• Strong governance and escalation pathways: Ensuring that complex or sensitive cases are managed transparently and with appropriate oversight.
The report identifies opportunities to further strengthen consistency when it comes to monitoring and evidencing customer outcomes as well as adapting customer journeys to meet diverse customer needs. The industry was also urged to enhance data sharing across the distribution chain to support joined-up outcomes and embed vulnerability concerns into product and service design, including testing and review.
To meet these challenges, the report brings good practice strategies to life through a series of case studies drawn from real scenarios across advice firms and lenders. Each example provides practical evidence of what good looks like in operational settings — and offers actionable ideas for firms seeking to strengthen vulnerability support within their own organisations.
Having identified areas where support is needed, the Council will launch Safe Steps in November 2025 — a toolkit designed to embed vulnerability best practice across the distribution chain.
Drawing on the principle that when dealing with a member of the Council, customers should expect trusted, tailored, transparent and thorough support, the in-depth document will feature structured specific guidance for a range of vulnerable circumstances, adviser prompts and real-life scenarios.
Lauren Peel, senior partner at Inclusive Outcomes, said: “The Financial Conduct Authority believes that almost half of UK adults has at least one characteristic of vulnerability so it is vital that sectors and organisations really consider how they can best support their customers. Today’s report recognises the leadership already being shown across the later life lending sector, while offering practical ways to deepen that work. The Consumer Duty has set the benchmark — now we must move beyond compliance to deliver thoughtful, tailored support that reflects the lived experience of customers."
Kelly Melville-Kelly, director of risk, policy and compliance at the Equity Release Council, added: "The sector has matured significantly in its approach to vulnerability — but the next phase must be about embedding consistency and driving continuous improvement. We know that individuals and organisations want to do the right things but at the moment, there is often a lack of practical, expert guidance to support complex interactions. Safe Steps, launching in November 2025, is designed to fill that gap and give advisers and lenders the tools to turn good intentions into confident, informed action.”
