Complaints handling for vulnerable customers

Do vulnerable customers react differently over the course of a complaint journey, and do they feel the same emotions as those complainants who are not vulnerable?

The opinions expressed here are those of the authors. They do not necessarily reflect the views or positions of UK Finance or its members.

Using data gathered while undertaking research for our Complaints Outlook 2022 report, Huntswood has taken a critical look at vulnerable customers, in particular their complaint journeys, and how they compare to the wider population. This data included surveying over 2,500 UK retail customers and 180 Complaint Handlers.

This research is timely, as the Financial Conduct Authority (FCA) recently announced a review of how firms are acting to understand and respond to the needs of customers in vulnerable circumstances.

Identification isn’t easy

We used a series of questions to identify vulnerabilities, which showed us that up to 44 per cent of customers were vulnerable. What’s more, 67 per cent of that vulnerable customer population didn’t even know it themselves. Further to this, 78 per cent of complaint handlers told us that they felt confident in identifying vulnerable customers, whereas over half (51 per cent) of consumers told us they didn’t believe their firm recognised they were vulnerable. This clearly shows a disconnect between how well firms think they are doing and what their customers think.

It’s emotional

In the Complaints Outlook 2022, we used the emotional response of consumers over the course of their complaint journey as a key metric of success. When looking at vulnerable customers in particular, their complaint journeys start from a more negative emotional baseline than their non-vulnerable counterparts. At resolution, vulnerable customers - where complaints are resolved to their satisfaction - tend to be less trusting of their provider than their non-vulnerable counterparts, while those whose complaints are not resolved to their satisfaction feel more sadness, but less anger than their non-vulnerable counterparts.

Customer impacts

We looked at various aspects of the complaint journeys of vulnerable customers, particularly with respect to retention. Overall, vulnerable customers are less likely to stay with their firms - only 51 per cent told us they were still with their firm at the conclusion of their complaint, compared to 60 per cent for non-vulnerable customers.

Looking specifically at how vulnerable customers are treated, there is a marked difference in retention between those customers who felt their firm did enough to help, given their circumstances, and were treated with respect, where 77 per cent of customers were retained. Compare this to only 28-32 per cent retention for those who felt firms didn’t do enough, or that they were not treated with respect.


We all know that it is difficult to identify people in vulnerable circumstances - in part because most people don’t even know it themselves. Identification of a customer’s vulnerability is just the first step in being able to reach an appropriate outcome in their complaint journey. So how do you ensure consistently good outcomes?

  • Good quality vulnerability training for customer-facing staff
  • Make it easy for customers to complain, ensure you have multiple channels and keep wait times low
  • Try to resolve complaints at first point of contact, if possible
  • Do more to support customers by having robust vulnerable customer policies and processes in place
  • Define what a good outcome looks like for different types of vulnerable customers
  • Monitor customer outcomes by carrying out end-to-end outcomes testing and reviewing management information regularly
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