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

The FCA’s Consumer Duty has made one thing unmistakably clear: firms must be able to evidence that customers are achieving good outcomes and that those in vulnerable circumstances are not left behind.

UK Finance, working with the Money Advice Trust, has developed a new PAIR model to help firms do this. At its heart, PAIR is a simple but powerful framework that helps organisations define, deliver, monitor, and improve customer outcomes. It breaks the work into four connected elements: Purpose, Action, Information, and Reaction. Together, these create a disciplined way of thinking about what customers should experience, how firms make that happen, and how they respond when things don’t go to plan.

Purpose: Defining the outcome you want to achieve

Every journey begins with clarity. Purpose is about defining the desired outcome. Not just in operational terms, but in human ones. A good Outcome definition should shift attention away from what firms do and towards what customers experience as a consequence. This clarity is especially important for vulnerable customers, whose needs, risks, and experiences may differ significantly from the wider population.

For example, offering real‑time balance alerts to your current account customers is not the outcome; the outcome of providing the alerts is enabling your customers to feel more in control and reducing financial anxiety.

Action: Delivering the outcome through design and support

Once the desired outcome is defined, firms must take deliberate action to deliver it. This includes product and service design improvements, staff training, communication strategies, reasonable adjustments, and specialist support. For vulnerable customers, these actions often determine whether they can access, understand, and use products in the same way as non‑vulnerable customers.

The FCA expects firms to ensure that vulnerable customers achieve outcomes that are as good as those for everyone else. That means removing barriers, anticipating needs, and designing support that is proactive rather than reactive. It also means avoiding poor outcomes, such as customers being unable to apply for products, understand terms, make payments, or raise complaints.

Information: Using insight to understand what’s really happening

Good intentions are not enough. Firms must gather and interpret insight to understand whether outcomes are being achieved. This includes retention rates, complaints analysis, behavioural trends, specialist service utilisation, and comparisons between vulnerable and non‑vulnerable cohorts.

Information is where the value lies, as it reveals whether interventions are working, whether customers are struggling, and where gaps exist. It also helps firms identify concerning trends early, before they become harm. 

Reaction: Taking action when outcomes fall short

The final element of PAIR is about responding when insight shows that outcomes are not where they should be. This might involve adjusting policies, redesigning products, improving communications, or providing additional support.  Reaction acts as our bridge between learning and improvement, and how we react to an unfolding situation or potential harm is essential for meeting Consumer Duty expectations.

Building capability through the Vulnerability and Consumer Duty Academy

For many organisations, embedding PAIR and delivering outcomes requires new skills, new thinking, and new confidence. The Vulnerability and Consumer Duty Academy, delivered by UK Finance and the Money Advice Trust, is designed to build exactly that capability. The Academy brings PAIR to life with tools and techniques practitioners can use in the real world, as well as providing a blend of practitioner case studies, interactive workshops, lived‑experience insights, and coursework designed to help participants embed vulnerability across their organisation.

The next cohort runs from October 2026 to March 2027, with the programme covering everything from identifying vulnerability and understanding customer needs to communication, design, support, monitoring, and evaluation. It equips professionals to meet FCA expectations, align with ISO 22458, and translate regulatory requirements into practical, meaningful improvements for customers. 

Conclusion

The PAIR model gives firms a structured, human‑centred way to deliver better outcomes and to ensure vulnerable customers receive outcomes that are just as good as everyone else. Embedded within the deep learning offered through the Vulnerability and Consumer Duty Academy, it provides a powerful foundation for organisations committed to fairness, inclusion, and excellence.