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What is the FCA’s vulnerable customer guidance and how should you treat customers in collections?

Written by Chris Smith | Sep 24, 2025 1:15:00 PM

The introduction of Consumer Duty marked a pivotal moment for the UK's financial services industry. But the real shift came afterwards when the FCA made it clear it would no longer just set expectations. It would now step up as a hands-on supervisor.

For collections teams, that change has major implications.

Treating vulnerable customers fairly has always been a regulatory focus. But now with the FCA taking on a more assertive supervisory role, the expectations are clearer, the oversight more intense, and the consequences of non-compliance more tangible.

So how should collections teams adapt?

A shift in tone from principles to proactive enforcement

Since July 2023, when Consumer Duty officially came into effect, the FCA has increasingly emphasized outcomes above all else. It’s no longer enough to show you have the right policies in place. You need to prove they work and that they’re delivering real-world benefits to your customers, especially the most vulnerable.

Since Consumer Duty has been implemented, the FCA has voiced a shift in focus in order “to understand how firms are improving consumer outcomes”. This means greater scrutiny of how you identify and support vulnerable customers, more data-driven oversight (including spot checks and firm-by-firm comparisons) and a demand for clear evidence (not just intentions) of fair treatment. 

Collections teams sit at the heart of this. You're engaging with customers at a moment of financial distress, often acting as the final touchpoint between hardship and deeper financial instability. The question isn't "Are you treating customers fairly?" It's "Can you prove you're doing so, and are your outcomes good enough?"

Why FCA expects vulnerable customer treatment as the focus

The FCA’s approach to supervision and its Consumer Duty focus areas both highlight vulnerable customers as a central priority. Here’s what they’re looking for, particularly in the collections space:

  • Early identification of financial stress and vulnerability
  • Personalized treatment plans based on individual circumstances
  • Supportive communication in the customer’s preferred format and tone
  • Clear segmentation to ensure high risk cases are prioritized
  • Evidence of reduced harm and improved customer outcomes

And importantly, these expectations aren’t exclusive to the UK. Regulators in Australia, Canada, the US, and the EU are watching closely. If the FCA model succeeds in improving consumer protection, it’s likely to set a global benchmark.

What this means for your collections strategy

Meeting these expectations takes more than training or empathy. Today’s collections teams rely on an infrastructure that provides fast access to live data, seamless segmentation of high risk accounts, automated and compliant workflows, and real time decisioning that adapts to customer needs.

Legacy systems simply can’t deliver that. They rely on batch processing, rigid rules, and manual interventions, none of which hold up under today’s regulatory spotlight.

Why configurability is the key to simplified compliance

In light of this supervision from the FCA, collections teams need the agility to adapt quickly, personalize strategies, and respond to regulatory scrutiny without friction. A configurable solution makes that possible, helping teams act quickly, operate transparently, and deliver the right outcomes for the people who need them most.

With the right system in place, collections teams can:

  • Ingest live data from any source to build a real time view of each customer
  • Detect signs of vulnerability early and assign treatment paths automatically
  • Simulate rule changes before they go live and monitor their impact
  • Create audit trails clearly demonstrating regulatory alignment
  • Empower business users to test and adjust strategies in minutes, not weeks

Ready to turn compliance into a competitive advantage?

Treating vulnerable customers fairly and supporting them thoroughly is a business imperative in the UK and beyond. With the FCA moving from principles to proactive enforcement, collections teams need more than good intentions. Real time insights, personalized strategies, and clear, provable outcomes are what make a real difference.

That’s exactly what FitLogic and Debt Manager were built for.

Debt Manager is the industry’s leading system for end-to-end collections and recovery, trusted globally for its power, flexibility, and ability to adapt quickly to changing regulations. Paired with FitLogic, our advanced decisioning solution, you gain real-time decision automation, seamless segmentation, and the ability to respond to customer needs with precision and care.

If you're navigating the demands of Consumer Duty or anticipating similar regulatory shifts in other regions, now’s the time to invest in technology that’s already built for it. Contact us at inquiries@crsoftware.com to find out more.