Report calls for greater consistency and practical support for vulnerable customers
The Equity Release Council, together with specialist consultancy Inclusive Outcomes, has released a review examining how the later life lending sector addresses customer vulnerability.
The report, Later Life Lending and Customer Vulnerability, outlines current industry practices and provides practical tools to help firms improve support for vulnerable clients.
The review details examples of effective approaches, including structured identification of vulnerable customers through fact-finding processes, targeted staff training, the use of vulnerability champions, and clear governance procedures for managing complex cases. These measures are intended to ensure early detection, tailored support, and appropriate oversight when dealing with sensitive situations.
The report also points to areas where the sector can improve, such as monitoring and evidencing customer outcomes, adapting services for diverse needs, and enhancing data sharing across the distribution chain. It encourages firms to integrate vulnerability considerations into advice, product design, and customer service, reflecting the needs of an ageing customer base and the potential for cognitive decline.
To illustrate best practice, the report features case studies from advice firms and lenders, offering real-world examples and actionable strategies for strengthening support for vulnerable customers.
The council plans to launch Safe Steps in November 2025, a toolkit aimed at embedding best practice across the sector. This resource will include detailed guidance, adviser prompts, and scenario-based examples to help firms implement consistent and effective support for vulnerable clients.
“The Financial Conduct Authority believes that almost half of UK adults has at least one characteristic of vulnerability, so it is vital that sectors and organisations really consider how they can best support their customers,” said Lauren Peel (pictured left), senior partner at Inclusive Outcome.
“Today’s report recognises the leadership already being shown across the later life lending sector, while offering practical ways to deepen that work. The Consumer Duty has set the benchmark — now we must move beyond compliance to deliver thoughtful, tailored support that reflects the lived experience of customers.”
For Kelly Melville-Kelly (pictured right), director of risk, policy and compliance at the Equity Release Council, while the sector has matured significantly in its approach to vulnerability, the next phase must be about embedding consistency and driving continuous improvement.
“We know that individuals and organisations want to do the right things but at the moment, there is often a lack of practical, expert guidance to support complex interactions,” she said. “Safe Steps, launching in November 2025, is designed to fill that gap and give advisers and lenders the tools to turn good intentions into confident, informed action.”
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