In Focus: How technology is being used to help vulnerable customers – and a plea to the FCA

When the FCA introduced its Consumer Duty rules in 2023, it specifically flagged vulnerable customers as being a key part of the regulations.

“Under the Consumer Duty, firms should act to deliver good outcomes for all customers, including those with characteristics of vulnerability,” the regulator stressed.

In its Guidance for firms on the fair treatment of vulnerable customers document, released in February 2021, the regulator defined this group as those “who, due to their personal circumstances, are especially susceptible to harm, particularly when a firm is not acting with appropriate levels of care”.

Over half of the customers that the UK insurance sector serves could be defined as vulnerable by this definition. In 2023, Watermelon Research posted results of a survey that showed 56% of 3,500 surveyed UK customers would be classified as vulnerable under the regulator’s Consumer Duty rules.

The introduction of the rules coincides with the increased use of technology within the insurance industry. And in June 2025, insurance technology provider RDT revealed that optimism for artificial intelligence (AI) proved to be high, with a strong consensus among respondents that the industry will adopt AI in a manner that benefits customers.

Indeed, some 34% of respondents were “very confident” this would be the case, with a further 40% “confident” – only 26% of respondents rated their confidence as neutral or less.

So, how are technology and software platforms helping the industry look after vulnerable customers? Tom Burroughs, chief technology officer at Synergy Cloud, told Insurance Times that “every insurer will have a slightly different philosophy and may have responded to the regulations and their best practices in slightly different ways”.

“So, they might look for slightly different characteristics or have slightly different internal processes around what they’re going to do when they find one of these cases and how they’re going to alert and escalate it,” he said.

Synergy Cloud provides end-to-end claims workflow technology to the insurance industry. Its software-as-a-service (SaaS) platform also contains a vulnerable customer module that is configurable.

Burroughs said: “For us, its been about putting something together that’s really configurable and really responsive to that and again, bearing in mind the number of different routes that claim and information might come into a particular insurer, how you detect at various different stages of the claims process.

“It’s really about understanding their philosophy is and what their approach to customer service is.”

Work in the industry

To ensure Consumer Duty rules were being followed, the FCA announced in March 2024 that it would conduct a review into how firms are acting to understand and respond to the needs of customers in vulnerable circumstances.

The review looked at firms’ understanding of consumer needs, the skills and capability of staff, product and service design, communications and customer service and whether these support the fair treatment of customers in vulnerable circumstances.

Outlining its findings a year later in March 2025, the FCA said: “Many firms had taken positive action and made good progress in supporting customers in vulnerable circumstances. We also saw evidence of this in our consumer research, through the positive experiences noted by some consumers.

“Across our work, it was clear the Consumer Duty has driven a renewed focus amongst firms on delivering good outcomes for customers in vulnerable circumstances.”

Highlighting an example of work Synergy Cloud has done within the insurance industry, Burroughs said: “We’ve done some work with an insurer recently that has put a programme in place where they are a multistream, multibrand organisation and what they’ve actually done is built up a central customer database that is able to hold vulnerability information across all the different lines of business that they do.

“We’ve been able to support with that. Firstly, when an insurance claim comes along, [we have been] able to receive information or intelligence that [the insurer] might have gained elsewhere through their interactions with that customer, so actually a claims team is on the front foot because they already know before they start talking to that customer that there is something to be aware of and vice versa the other way around.

“So, through that claims experience, they begin to understand something about that customer that needs to be shared and it can be centralised and made available to their other customer frontline team, so everyone is aware on the front book.

“So, you are really genuinely treating that customer as an individual and understanding everything about them across the piece.”

Meanwhile, Matthew Porter, chief executive at Bridgetech, gave two examples of work his firm has carried out within the industry.

The firm specialises in providing data-driven propositions that aim to help to insurers enhance efficiency, reduce costs and improve outcomes.

Porter highlighted that his firm had created an animated video that aims to further help customers through the claims journey and that it had also deployed an artificial intelligence (AI)-powered chatbot.

“Some people really don’t like talking on the phone and I know some vulnerable customers don’t like speaking,” he said.

“They feel very anxious speaking to anybody on the phone.”

Preferring technology

According to research done by technology advisor Ensono, 56% of UK consumers prefer to speak to someone over the phone about their insurance.

Carried out in 2023, the research surveyed 500 UK insurance customers, asking them to rank their preferred channels for interacting with their insurer.

“It is important that insurers’ plans for transformation do not lose track of what the modern insurance consumer actually wants from their provider,” said Steven Jones, consulting director at Ensono.

“Customers clearly are committed to human-human contact when managing an insurance policy.

“Insurers need to make sure that these core channels are not neglected and they continue to provide a reliable and trusted service to support customers’ needs.”

Porter highlighted that there are “communities that really want to talk on the phone and there are communities that really don’t” and said he was “initially quite sceptical about what kind of uptake we’d have” when it came to the work around AI his firm has undertaken.

However, he said: “The uptake has been extraordinary and the uptake is just growing and growing and growing for the animated videos, for the AI-powered chatbots.

“And the AI-powered chatbots are getting smarter and smarter overtime. As the chatbots and the technology grows and develops and gets better, it is seeing uptake.”

Data and FCA plea

To create these workflows for vulnerable customers, one thing that is key is data – and the amount of data available today is increasing at an exponential rate.

Essentially, the more data that is provided and how specific it is usually means a more accurate analysis is available, meaning that better workflows can be created.

Burroughs said: “A lot of the focus has been on identifying at the beginning how we take the data that we are generating back into our product intelligence and how we understand what the demographic of customers really looks like.

“Over time, as we get better at identifying what our customers are experiencing, that really ought to inform the product design from the beginning.”

He added that it would be “really welcome” if the FCA were to provide more guidance and any more specifics in terms of what its expectations are of software platforms”.

“It would certainly help vendors like ourselves to know we’re able to work in a way that is sort of recommended or approved by the regulator,” Burroughs said.

“[Then] we know we can provide a bit of confidence around what our platform is doing to keep insurers on the right side of regulation.

“The more information the better. It helps us as a vendor and helps us help our customers in terms of what they need to do.”