Mova’s Inclusive by Design research report, created in partnership with AbilityNet, explores how poorly designed services can create avoidable barriers for people with vulnerabilities, while showing that inclusive design, accessible channels and responsive human support can reduce harm and improve outcomes for everyone.
In this supporting article, Ellen Martin, Research and Evaluation Manager at AbilityNet, provides further context behind the research, exploring what vulnerability means, why it can affect anyone, and how inaccessible services can create or deepen barriers for people trying to access essential support.
The concept of a ‘vulnerable customer’ was coined by the Financial Conduct Authority (FCA) in 2015. According to the FCA:
“A vulnerable customer is someone who, due to their personal circumstances, is especially susceptible to harm – particularly when a firm is not acting with appropriate levels of care.”[1]
Vulnerability is understood to have four key drivers: life events, both physical and mental health issues, low resilience to cope with financial or emotional shock, and low capability.[2] According to the FCA, at least 1 in 2 adults in the UK are classed as showing one or more characteristics of vulnerability.[3]
In April 2025 this number is thought to be higher, with 60% of adults in Great Britain reporting at least one characteristic that makes them potentially vulnerable financial services customers.[4] As noted by the FCA, not all of these customers will experience harm, but they are at greater risk of harm. Equally, “all customers are at risk of becoming vulnerable”, especially considering the fluid nature of the key drivers.[5] Anyone can be vulnerable, and vulnerability can change over time.
Life events
In 2024, the FCA reported that 1 in 5 UK adults had experienced negative life events (10.9 million people).[6] Negative life events can often be sudden and unexpected including experiencing bereavement, job loss, or moving house. Many of these life events at best cause administrative stress, and at worst can have long-term health impacts.
- 72% of people were reported to have been bereaved in a five-year period in the UK, with only 27% feeling they received support at the right time.[7]
- In early 2026, there were around 4 redundancies for every 1,000 employees.[8]
- Over 1 in 5 households had moved in a three-year period in the UK. Private renters are more likely to move house, compared to those who own their house, or social housing renters.[9]
All these life events are likely to increase contact with key services; to update contact details, make claims or payments, and ask for advice or to raise a complaint.
Health issues
Poor physical and mental health is permanent for some, and temporary for others. Some people live with physical health conditions or diseases, impairments, and mental health conditions. Whilst for many others, including those with permanent conditions, they experience temporary poor health, such as an operation, a shorter-term disease, or a poor mental health episode.
- 1 in 10 UK adults were reported as vulnerable due to poor health in 2024.[10]
- 1 in 4 people in the UK are predicted to be disabled – this is 16.8 million people.[11]
- 1 in 5 people report experiencing a common mental health problem (e.g. anxiety or depression) in any given week in England.[12]
- For those who are unable to interact fully with services, they often rely on unpaid carers – 4.7 million people provide unpaid care in England, and 1.4 million of them are caring for more than 50 hours a week.
Health conditions and disability may increase the need to interact with services, especially health services, whilst also being more likely to come across barriers accessing these services.
Low resilience
Low resilience is understood as a person’s ability to cope with financial or emotional shock – which can be impacted by life events e.g. loss of a support network, reduced income, or lack of savings. This was the leading vulnerable characteristic in 2024, with 1 in 4 adults having low resilience (14.3 million people).[14] Financial vulnerability was the most prevalent driver of vulnerability, covering 43% of Great Britain‘s population in 2025.[15]
- 18% of adults in Great Britain are considered financially vulnerable, meaning they fit three out of four metrics: borrowed more money than usual in the last month, unable to pay an expense of £850, unable to save any money in the next 12 months, and found energy bills difficult or very difficult to pay.[16]
- 1 in 5 people in the UK are in poverty.[17]
- Financial literacy is lower among certain groups, including women, those with low incomes or educational attainment, ethnic minorities, young people and older people.[18]
For those without financial stability, the move to digital services and the reduction of in-person provision, means owning a device (often two for allowing two-factor authentication) and having a connection to the internet are becoming more pressing. This puts further financial strain on those already struggling. In 2025, 23% of households had difficulty affording their communication services – this was more likely for those in receipt of benefits and those with a resident with an impairment or health condition.[19]
Low capability
Although low capability can be understood as having low English proficiency, poor literacy or numeracy skills, or having learning difficulties, it can also be understood as having low digital skills or low confidence in managing money. 9.3 million UK adults had low capability in 2024 (17%).[20]
- 17 million adults (49% of the working age population of England) have the numeracy level expected from primary school children.[21]
- 9% of the population in England and Wales don’t have English as a main language; 1.8% could not speak English well or at all.[22]
- 8 million UK adults don’t have the foundation level of digital skills. People who are not confident using the internet are 19% more likely to feel stressed or overwhelmed when they think about their finances.[23]
Digital first approach
The level of someone’s digital skills is an ever-increasing driver to vulnerability. As more key services move to ‘digital first’, the confidence, ability, and access to the digital world becomes more important. There is limited information about services across sectors and the extent of digitalisation. However, we do know that key services such as local and national government, water, broadband, banking, insurance, and health are increasingly using digital avenues to communicate with their users. There is currently an inconsistency across services, and a lack of choice. This report highlights the importance of choice in inclusive design.
For those who cannot easily get online, a digital first approach cuts them off from essential services. Equally, for those who cannot easily use the phone, or access physical services, accessible and well-designed online options are essential.
- 15% of UK adults don’t have a foundation level of digital skills, and 8% don’t have essential digital skills for life.[24]
- 1 million adults have the lowest level of digital capability and are more likely to lack confidence in protecting themselves against fraud.[25]
- Age is the most significant driver of digital capability, with those with the lowest digital capability most likely to be aged 70 and older.[26]
Although there are groups who are more likely to be digitally excluded, anyone can be excluded at any time. This could be due to not affording devices or connectivity, lacking the skills or confidence, or the service they are trying to use is not accessible.
Reframing vulnerability
Vulnerability is more complicated than distinct categories, many people, as the statistics above and the stories in Inclusive by Design show, fit into multiple categories. Two people who have recently been bereaved may require completely different access needs to a service. Although it is important that the drivers for vulnerability are recognised, they cannot be fully supported without inclusive and flexible services.
When considering the drivers of vulnerability, it becomes clear that anyone can become vulnerable at any time. However, research shows that “many wouldn’t self-identify as vulnerable, let alone discuss their circumstances with a customer service advisor”.[27] Rather than individuals needing to self-identify, and therefore recognise themselves as vulnerable, this report suggests services should provide inclusive design and choice for everyone, not just identified vulnerable customers.
To avoid the stigmatisation of vulnerable, and recognise the influence and power services hold, this report applies the social model of disability developed by disabled people to the concept of vulnerable customers. The social model of disability describes people as being disabled by barriers in society, not by their impairments.28 Therefore, if modern life was designed accessibly, and with impairments in mind, disabled people would not be excluded or restricted. This puts the onus of removing barriers on wider society; structures, institutions, and organisations, rather than the individual. The same can be applied to vulnerability; it is the services that marginalise, or vulnerabilise, customers; the barriers put up in terms of service access, attitudes, and policies that make people vulnerable. An older person with limited digital skills and no computer is made vulnerable by a service that only offers a webchat to contact them. Equally, a wheelchair user is made vulnerable by a service that only offers in-person support in an inaccessible building.
Inclusive by Design recognises the drivers for vulnerability, and those individuals who are high risk – and brings their stories to the forefront, whilst also recognising that it is inaccessible services that make people vulnerable.
By Ellen Martin
Research and Evaluation Manager, AbilityNet
Read the full Inclusive by Design report here
[1] Financial Conduct Authority, Guidance for firms on the fair treatment of vulnerable customers, 2021
[2] NICA and FOCALDATA, The Changing Face of Vulnerability, 2025.
[3] Financial Conduct Authority, Financial Lives Survey 2024, 2025.
[4] YouGov, Consumer Duty: 60% of GB adults show at least one characteristic that makes them potentially vulnerable customers, 2025.
[5] Financial Conduct Authority, Guidance for firms on the fair treatment of vulnerable customers, 2021
[6] Financial Conduct Authority, Financial Lives Survey 2024, 2025.
[7] Sue Ryder, A better grief, 2019.
[8] ONS, ‘Redundancies’, 2026.
[9] GOV.UK, English Housing Survey data on new households and recent movers, July 2025.
[10] Financial Conduct Authority, Financial Lives Survey 2024, 2025.
[11] House of Commons Library, UK Disability Statistics: Prevalence and Life experiences’, 2024
[12] Liubertiene, G., Sloman, A., Morris, S., Bhavsar, V., Clark, C., Das-Munshi, J., Jenkins, R., McManus, S., Oram, S., & Wessely, S. (2025). Common mental health conditions. In Morris, S., Hill, S., Brugha, T., McManus, S. (Eds.), Adult Psychiatric Morbidity Survey: Survey of Mental Health and Wellbeing, England, 2023/4. NHS England
[13] ONS, Census 2021
[14] Financial Conduct Authority, Financial Lives Survey 2024, 2025.
[15] YouGov, Consumer Duty: 60% of GB adults show at least one characteristic that makes them potentially vulnerable customers, 2025.
[16] YouGov, Consumer Duty: 60% of GB adults show at least one characteristic that makes them potentially vulnerable customers, 2025.
[17] House of Commons Library, Poverty in the UK: statistics, 2026.
[18] The London Foundation for Banking & Finance, Accelerating Progress: Financial Capability in the UK, 2025
[19] Ofcom, Communications Affordability Tracker, 2025
[20] Financial Conduct Authority, Financial Lives Survey 2024, 2025.
[21] National Numeracy, The Essential of Numeracy: A new approach to making the UK numerate, 2017.
[22] ONS Census 2021
[23] Lloyds Banking Group, Essential Digital Skills, 2025
[24] Lloyds Banking Group, Essential Digital Skills, 2025.
[25] Lloyds, Digital Consumer Index, 2024.
[26] Lloyds, Consumer Digital Index, 2024.
[27] NICE and FOCALDATA, The Changing Face of Vulnerability, 2025.