Firms mustn’t neglect vulnerability when offering targeted support – MorganAsh

Firms looking to offer the Financial Conduct Authority’s (FCA) new targeted support must not neglect the customer vulnerability requirements set out in Consumer Duty, MorganAsh has warned.

The regulator announced the "near final rules" for the targeted support framework last week, with firms being able to submit applications in March 2026, ahead of the provisional go-live date in April, which is subject to necessary legislative changes.

The move will enable firms to make recommendations to consumers in segments with particular characteristics, without a full, in-depth individual assessment.

According to the FCA, the new service will support at least 18 million people over the next decade, increasing access to and providing extra help with investments and pensions.

However, MorganAsh has warned that firms must not overlook the requirements of the regulation, specifically identifying vulnerable customers and understanding their characteristics and needs.

Managing director at MorganAsh, Andrew Gething, said that the firm welcomes the introduction of targeted support.

He added: "Targeted support will allow firms to make recommendations on segments of consumers with similar financial positions, providing a bridge between limited or generic guidance and full advice, and encouraging firms to offer an affordable and accessible alternative.

"Given that it is underpinned by Consumer Duty, firms will still need to comply with FG21/1 on vulnerability and identify and support those with vulnerable characteristics, whether that’s health, negative life events or low capability.

"According to the FCA’s Financial Lives Survey, this is nearly half of the population. Firms looking to offer this service need to know who their vulnerable customers are to determine if targeted support is even appropriate, never mind to meet the wider duty requirements to identify, record, monitor and report on customer vulnerability and outcomes."



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