In 2026, Consumer Duty shifts from an implementation period to enforcement. As such, if you are a regulated firm, you need more than good intentions and a few adaptations to comply. With a decade of experience in supporting companies to better serve vulnerable customers, we want to share an overview of Consumer Duty priorities in 2026.

Establish a Caring Company Culture

Since 2015, the FCA has introduced expectations around the fair treatment of vulnerable customers. From the outset, they made it clear that this was more than a tick-box exercise. What they want to see is a deeper understanding of how life experiences impact access to services, along with measures to break down the barriers.

It is recognised that high standards result from principles that are successfully embedded in the company culture. It’s not enough to say that you care about customers; it has to be consistently demonstrated at all stages of the customer journey.

To achieve this, all employees need training to understand and emotionally connect with the diverse and expansive range of conditions, life events, resilience and capabilities that can lead to potential vulnerability. In addition, they need to be equipped to use this insight to improve services.

We’ve seen a lot of focus on frontline employees, which has driven improvements in vulnerable customer service. However, our feeling is that there is scope to extend this across the team, especially to those responsible for product design, service procedures, marketing and data analysis. When they are also better aware of customers’ needs, we expect to see a more sustained shift towards a caring company culture.

Effective Information Collection & Monitoring

We all have so much data at our fingertips that it can be challenging to identify which is of value for driving meaningful change. However, the FCA is focused on evidence that firms are providing fair value and good outcomes for vulnerable customers. So, what do you need in place?

In terms of Consumer Duty, insightful Management Information (MI) includes:

• Customer journey mapping, including web analysis and call monitoring, to establish what is required at each point of interaction to engage and empower customers to make informed decisions.
• Proactive encouragement of customer and employee feedback, from which to identify sentiment, trends, and actions which have led to positive outcomes.
• Root cause analysis to understand what factors influence quality service, fair value and trust.
• Customer acquisition and attrition rates, and what has influenced these decisions?
• Service improvement recommendations and product reviews from people with lived experiences of vulnerable circumstances.
• Thorough value assessments to evidence fair pricing.

With regular monitoring and review, this MI can help you shape inclusive and supportive services that genuinely lead to continuous improvement. Equally, it can inform tailored support to address specific customer needs.

Combat Poor Outcomes & Harm

While working on ways to better serve customers, we also need a clear understanding of what can exacerbate vulnerable circumstances. Unfortunately, there are still shocking reports of failings in basic customer service. These can result from issues including outdated policies, insufficient training, poor performance management, and a lack of respect for customers or employees.

Of course, isolated mistakes happen. However, we all have a responsibility to minimise negative experiences that harm company reputations, as well as customer outcomes.

In addition, there is the growing risk of issues, including fraud and scams, as services become increasingly digitalised. For this reason, data protection and secure infrastructures are essential.

In addition, human oversight and involvement have to be integrated into every digital process. AI has many benefits, yet it lacks human nuances and emotional connections, which can be the difference between an adequate and exceptional customer experience.

Focus on Continuous Improvement

In 10 years of supporting firms with the fair treatment of vulnerable customers, we’ve seen significant progress. Banks, insurance companies, local authorities and utility providers are among those to embrace change and enable more of the UK population to access and benefit from essential services. Yet, this is the start of the journey, and there is considerable scope to build on good practices. We welcome the opportunity to support your next steps with our specialist training, consultancy, resources and events.

To discuss options that align with your 2026 priorities, we invite you to book a call with Helen.