FG21/1 — Vulnerable customers guidance

Category: Compliance & AML · Reviewed by Matt Bartlett, Director · Founder · Last reviewed June 2026

The FCA’s Finalised Guidance, published in February 2021, setting out expectations for firms on the fair treatment of vulnerable customers — covering understanding needs, skills and capability of staff, taking practical action, and monitoring outcomes.

Definition

FG21/1 is the FCA’s Finalised Guidance on the fair treatment of vulnerable customers. Published 23 February 2021, it set the FCA’s pre-Consumer Duty expectation for firms’ vulnerability frameworks. With the Consumer Duty operative from 31 July 2023, FG21/1 sits alongside PRIN 2A as the principal source of FCA expectations on vulnerability.

Legal / Regulatory basis

FCA Finalised Guidance FG21/1 (Guidance for firms on the fair treatment of vulnerable customers, February 2021). Non-binding guidance interpreting Principles 6 and 7 of PRIN at the time of publication, and now read with Principle 12 (the Consumer Duty).

How it works in practice

FG21/1 sets four expectations: (1) Understanding the needs of the firm’s customer base — including the prevalence of vulnerability indicators; (2) Ensuring staff have the skills and capability needed to identify and respond to vulnerability; (3) Taking practical action — adapting products, services, communications and customer service; (4) Monitoring and evaluating outcomes — using MI to demonstrate fair treatment is being delivered. The guidance covers the four drivers (Health, Life events, Resilience, Capability), the dynamic and intersectional nature of vulnerability, the importance of disclosure-friendly conversations, and the operational implications.

Common variations

The guidance applies across regulated sectors with relevant adjustments. For insurance distribution, FG21/1 maps directly onto the ICOBS 2 fair treatment duty, the ICOBS 5 demands and needs identification, the ICOBS 8 claims handling rules, and the cross-cutting Consumer Duty rules.

Example

Apex’s annual vulnerability training programme is mapped to FG21/1 — staff are trained on the four drivers, on hidden vulnerability, on appropriate language, on signposting to specialist support, and on the firm’s escalation and accommodation procedures. The annual board report on Consumer Duty includes vulnerability-specific MI.

See also

• Vulnerable customers
• PRIN 2A — The Consumer Duty
• Cross-cutting rules
• Four Consumer Duty outcomes
• ICOBS 2 — General matters and fair treatment

References

FCA Finalised Guidance FG21/1 (Guidance for firms on the fair treatment of vulnerable customers, February 2021). FCA Handbook, PRIN 2A.

Last reviewed

By Matt Bartlett, Director, on 2026-06-11.

This entry is part of the Apex Insurance Wiki. Last reviewed by Matt Bartlett on 2026-06-11. Apex Insurance Brokers Limited, FCA FRN 724952, Companies House 07014570. Not regulated advice — consult your broker on your specific position.