Duty of care: Moving the needle from compliance to strategy

Identifying and supporting vulnerable customers has long been a pillar of the Consumer Duty, but the landscape has recently shifted. With the finalisation of PS25/19, the Financial Conduct Authority (FCA) has moved from guidance to a hard mandate - vulnerability identification is now a core requirement for complaints reporting. By 2027, firms must be able to quantify not only which complainants were vulnerable, but specifically where a failure to address that vulnerability caused the issue. With 2026 as the critical implementation window, the era of tick-box compliance is over. Thi...