CII launches vulnerability guide to support fair customer outcomes

The Chartered Insurance Institute (CII) has published a new guide to help insurance and personal finance firms manage customer vulnerability more effectively. 

The Managing Customer Vulnerability in Insurance and Personal Finance: A Practical Implementation Guide was launched at an event in London, attended by around 50 people including press and stakeholders. 

The Guide aims to help firms identify, support and deliver fair outcomes for vulnerable customers. 

Adam Harper, director of strategy, advocacy and professional standards at the CII, Andrew Gething, managing director at Morgan Ash, Claire Massey, CEO of Claims Guardians, Eddie Grant, PFS board member and Disability Access Ambassador for insurance, Jonathan Pearson, head of consumer policy and outcomes at the FCA, and Vanessa Riboloni, head of research and insight at the CII, presented the Guide.

The Guide includes a six-step framework: identify, quantify, monitor, support, adapt and report. 

There is a focus on data infrastructure and outcomes reporting, as well as guidance on leadership, training and data sharing. 

It also offers advice for firms of different sizes, and practical tools like checklists, case studies and system selection criteria. 

The Guide was developed with input from vulnerability experts, customer experience practitioners and people with lived experience.

Matthew Hill, CEO of the CII, said: “The CII Group is delighted to share this guidance with insurance and financial planning firms and professionals. 

“Effective vulnerability management is about more than regulatory compliance. 

“It is about creating a fairer, more resilient system for all customers. In embedding the principles of this guide into their culture and operations, firms will not only meet the expectations of good practice, but also contribute to the development of a sector that conscientiously strives to meet the needs of every customer.”

Carla Brown, president of the PFS, said: “I welcome this guidance as a significant step forward for our profession. 

“Supporting clients in vulnerable circumstances is fundamental to good financial planning, and this practical framework gives firms clear direction on how to embed that responsibility into everyday practice. 

“Our community is committed to raising standards and ensuring that every client, whatever their situation, receives the care, understanding and outcomes they deserve.”

Brown added: “This publication will help professionals across the sector strengthen their approach and, ultimately, deliver better experiences for the people who rely on us most.”

Claire Massey, founder of Claims Guardians, said: “As both a compliance professional and someone who has personally experienced vulnerability through the insurance process, I am proud to have contributed to this guidance. 

“It represents a meaningful step forward in helping firms translate regulatory expectations into real empathy, fair decision-making and timely action. 

“Vulnerability is not a theoretical concept; it’s a lived reality that can affect any of us overnight.” 

Massey added: “This guide ensures that when things go wrong, customers in vulnerable circumstances are supported and not further disadvantaged by the very systems designed to protect them.”

Johnny Timpson, chairman of Absolute Military, said: “As a Financial Inclusion Commissioner and as Chair of specialist armed forces broker Absolute Military I welcome the Chartered Insurance Institute’s Vulnerable Customer Guidance that supports the ambition of the Government’s Financial Inclusion Strategy and FCA Consumer Duty Regulation. 

“I’ve long held that the test of our progress as an industry and profession together with the delivery of our professional body’s Royal Charter promise should not simply be measured in adding to the abundance of those we serve and/or improving their resilience to perils and shocks but importantly, in ensuring that the vulnerable customers we serve enjoy the same access, inclusion, protections and outcomes as anyone else.”

Eddie Grant, UK Cabinet Office Disability and Access Ambassador (insurance and financial planning), said: “As the UK Cabinet Office Disability and Access Ambassador for the Insurance and Financial Planning sector, I welcome the publication of the Managing Customer Vulnerability guide – a timely and practical resource that supports firms and individuals in embedding inclusive practices and responding meaningfully to vulnerable client circumstances. 

“It is a great example of the Professional Body convening power, bringing together a diverse range of expertise for the benefit of wider society. 

“This guide offers actionable steps that firms of all sizes can take to better understand, anticipate, and meet the needs of customers who may be at greater risk of harm.” 

Grant added: “I am particularly encouraged by the guide’s emphasis on enabling elements and proportionate approaches building trust, removing barriers and ensuring that everyone can access the financial services they need to thrive. 

“I urge our members and beyond to read, share, and implement the insights in this guide.”

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