Vulnerable Customer (FCA Definition)

Under FCA Finalised Guidance FG21/1, a vulnerable customer is someone who, because of their personal circumstances, is especially susceptible to harm, particularly when a firm is not acting with appropriate care.

The guidance describes four drivers of vulnerability: health, life events, resilience, and capability. Vulnerability is not a fixed label on a group of people; it is a state anyone can move into, temporarily or permanently, and digital journeys can either ease it or make it worse.

The FCA expects firms to identify these susceptibilities and act on them, which means knowing where a journey is hard for someone under stress, with low confidence, or with a cognitive difference. Testing with participants who experience those conditions surfaces the specific points of harm before a real customer hits them.

For OpenScouter this is a downstream use case. We are a usability testing platform; producing vulnerable-customer evidence is something regulated firms can ask the same method to do.