Friday, August 22, 2025
A practical guide for complaint case handlers. Dealing with vulnerable customers
Introduction
If you’ve worked in complaints for more than a week, you know that no two customers are the same, and some need more than the standard process to get to a fair outcome.
This guide is written for complaint case handlers and frontline teams managing real cases day-to-day.
Vulnerability isn’t rare. It’s part of complaint handling, and the responsibility sits with you, not the customer, to identify whether additional support is needed.
A vulnerable customer 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. (FCA)
This relate to a long-term illness, sudden bereavement, fluctuating mental health, or even retirement. The point is that you will not always be told. Often, it’s down to you, as the person speaking to the customer, to spot the signs, record them accurately, and adapt how you handle the case.
Under the FCA’s Consumer Duty, your actions need to result in outcomes for vulnerable customers that are as good as those for everyone else.
🎗️ Some customers may object to being labelled as ‘vulnerable’, and we've found that phrases such as ‘requiring additional support’ are much more appreciated.
1. Recognising vulnerability in real life
The FCA describes four drivers of vulnerability and some of the characteristics that may sit under each one:
Health: includes physical disability, severe or long-term illness, mental health condition, addiction, or low mental capacity.
Life events: includes bereavement, relationship breakdown, domestic abuse, caring responsibilities, and migration.
Resilience: includes low emotional resilience, erratic income, and over-indebtedness.
Capability: includes low knowledge of managing finances, poor literacy or numeracy skills, and poor English language skills.
Some cases are obvious. A customer may tell you they’ve been diagnosed with a long-term illness, or you may hear that English isn't their first language. But many cases need to be indentified through active listening.
Examples:
A customer struggling to keep track of what you’ve said may be experiencing cognitive difficulties.
Someone who avoids phone calls might have anxiety or hearing impairments.
A change in tone or urgency could indicate sudden life changes such as job loss, caring responsibilities, or another major life event.
💡 Tip: Don’t automatically dismiss an unpleasant or unusually mannered customer. If something doesn't seem right, maybe there may be more going on. If you’re unsure, flag it for review with your team leader.
2. The 4 R’s to support vulnerable customers
The 4 R’s are a simple way to structure your approach when you suspect or confirm vulnerability:
Recognise: Identify vulnerability markers through active listening, questioning, and observation.
Record: Capture details clearly in the system so that the customer doesn’t have to repeat their circumstances to multiple people.
Respond: Make reasonable, proportionate adjustments that meet the customer’s needs without causing unnecessary delay.
Review: Reassess regularly, especially for transient or intermittent vulnerabilities, to make sure adjustments remain appropriate.
Following the 4 R’s will help you act consistently, build an evidence trail, and support good outcomes, no matter who picks up the case next.
3. Using the right frameworks and making them routine
Frameworks aren’t just for training courses. They’re a safety net for when you’re working under pressure. Here are two well-known frameworks recognised by the FCA and Money Advice Trust:
TEXAS: Thank, Explain, eXplicit consent, Ask, Signpost: used to manage disclosure and record details lawfully.
IDEA: Identify, Design, Evaluate, Adjust: works well with the FCA's MALD (monitor, analyse, learn and develop) strategy to build an organisation-wide approach.
Another approach referenced across UK vulnerability guidance and good practice is BRUCE
BRUCE: Behaviour, Remembering, Understanding, Communicating, Evaluation: useful when you need to assess capacity and resilience.
Other practical conversation techniques can also help complaint case handlers identify vulnerability more effectively in live conversations.
TED: Tell, Explain, Describe: helps customers speak in their own words, giving you a clearer picture of what they are experiencing without leading them towards a yes or no answer.
Silence also matters and shouldn’t be seen as an awkward part of the conversation. Some customers need extra time to process information, remember details, or feel comfortable enough to explain what’s really going on. A short pause can give them the space they need, and will often help you more than rushing to get the answer to the next question.
The Listening Wheel: helps you listen for more than the headline issue, including emotional cues, what may be left unsaid, and whether the customer may need communication or process adjustments.
For a fuller explanation of The Listening Wheel, Samaritans provides a short handout on practical listening techniques, including open questions, summarising, reflecting, clarifying, encouragement, and reacting.
When your system prompts you to run through TEXAS or BRUCE, follow it step by step. Use TED questions, active listening, and short pauses to give the customer space to explain what they need. These checks help you record and respond consistently, and show clearly why the support offered was appropriate when the case is reviewed later.
4. Adjusting without adding unnecessary delay
Once vulnerability has been identified, your role is not to slow the complaint down. It is to act quickly and thoughtfully so the customer can engage with the process more easily.
This may mean offering a different communication channel, using plain language instead of technical terms, or breaking the next steps into manageable parts. In some cases, it may help to provide a short written summary after a phone call, offer information in a more accessible format, or arrange support from a trusted third party where appropriate.
It’s also worth checking understanding before moving on. Asking the customer to explain the next step in their own words can highlight where something is still unclear and give you the chance to put it right early. These are often small adjustments, but they can make the complaints process feel far more manageable for someone who’s already under pressure.
Record these adjustments clearly, along with any review or expiry dates if the need for additional support may be temporary.
5. Why collecting evidence is your shield
You might think you’re doing the right thing, but without clear notes, your work can’t be defended. The Financial Ombudsman Service (FOS) often upholds or rejects complaints based on the quality of reasoning and evidence: a written summary after the event isn’t enough.
This is why your notes, emails, and decisions need to show the:
Vulnerability markers you identified.
Adjustments you made.
Reason as to why the adjustments were proportionate.
If you want to see how this evidence fits into a firm’s systems, data, and compliance controls, read Embedding vulnerability in complaint handling. It gives a bigger picture of how these individual actions will help your firm meet compliance and governance objectives.
6. Learning from real cases
Regulators take vulnerability seriously because missed needs have real-world consequences.
For example, in a case study shared by the FOS, a consumer complained that their bank acted irresponsibly after they made a high volume of gambling transactions. The ombudsman found that the bank had not identified or acted on clear signs of potential vulnerability and financial harm and upheld the complaint.
Missing vulnerability indicators can directly impact a customer’s well-being and your firm’s regulatory risk.
Handling vulnerability well isn’t about doing more work; it’s about supporting your customers and following the right steps, every time. Recognise. Record. Respond. Review. This is how you protect your customer, your decision-making, and your firm’s regulatory risk.
Related guide to help deal with root causes of vulnerability in complaints
Where the same vulnerability issues keep showing up in complaints, using the Fishbone diagram and 5 Whys can help teams identify root causes and reduce repeat harm.
Frequently asked questions: supporting customers who need additional support in complaint handling
These FAQs cover common questions complaint case handlers ask when managing complaints involving customers who may need additional support in FCA regulated firms.
What counts as a vulnerable customer in complaint handling?
A vulnerable customer in complaint handling describes circumstances that make a customer especially susceptible to harm. In practice, this can relate to health, life events, resilience, capability, or communication barriers whether short or long-term. The key is to respond to the needs you observe, not to classify the person.
How should a case handler record vulnerability in a complaint case??
A case handler should record vulnerability in line with the guidance and process set by their firm. The record should be consistent and capable of being evidenced later: what you observed, what the customer disclosed, what support was offered, what adjustments were made, and how this affected the communication or decision making approach. Focus on facts, not assumptions.
What is one of the biggest mistakes teams make when handling vulnerable customer complaints?
One of the biggest mistakes teams make is treating vulnerability as a fixed, scripted process. Each customer’s circumstances are different and need a response shaped by empathy, fairness, and good judgement. When support becomes too procedural, it is more likely to be inconsistent, weakly evidenced, and less helpful to the customer.
What tools can help complaint case handlers identify vulnerability in a conversation?
Practical tools include frameworks such as TEXAS, IDEA, and BRUCE, along with conversation techniques such as TED questions, active listening, and allowing silence where the customer needs time to think. The Listening Wheel can also help handlers listen for emotional cues, what has not been said, and whether communication or process adjustments may be needed.
How do you communicate with a customer who may need additional support during a complaint?
Start by slowing the conversation down just enough to understand what the customer needs. Use plain language, avoid jargon, ask open questions, and check understanding before moving on. Where appropriate, offer a different communication channel, a written summary, an accessible format, or support from a trusted third party. The aim is to make the complaint process easier to follow without creating unnecessary delay.
How do you encourage a customer to disclose information without making the conversation uncomfortable?
You cannot force disclosure, but you can create the conditions for it. Open questions such as Tell, Explain, and Describe can help customers speak in their own words. A calm tone, short pauses, and not rushing to fill silence can also make it easier for someone to explain what is really going on. Customers are more likely to share useful information when they feel listened to, not interrogated.