Rachel Lam is the Interim Ombudsman Managing Director at the Financial Ombudsman Service.
It was a privilege to speak about vulnerability at the 2026 PIMFA Women’s Symposium – an event that continues to bring together leaders and professionals across investment and financial advice and create space for timely conversations.
These conversations about supporting vulnerable customers are crucial and sit at the heart of trust in financial services.
Why vulnerability matters
Vulnerability matters because it is deeply connected to how people experience financial harm. While women are disproportionately affected by issues such as economic and domestic abuse, vulnerability itself is not inherent to any one group. Rather, it is shaped by circumstance – life events, power dynamics, financial shocks, or structural inequalities.
Vulnerability is a shared system issue, which is reflected in HM Treasury’s Financial Inclusion Strategy. While the Financial Ombudsman Service does not deliver that strategy directly, our role underpins it – by providing a free, independent and accessible route to redress.
Each year, we resolve around 200,000 disputes. Each one reflects a moment where a consumer believes something has gone wrong – and where the system must respond fairly, consistently and with care.
Vulnerability can sit at the heart of these cases, particularly as financial products become more complex. In areas such as pensions and investments, individuals are now making high-stakes decisions that can shape their financial future, often during periods of uncertainty or distress.
Understanding harm properly
Our role is not to lower evidential thresholds or abandon impartiality. It is to ensure that people can engage meaningfully with our process – that they understand what is happening, feel heard, and are able to participate on an equal footing. Fair process is the foundation of fair outcomes.
Vulnerability at the heart of our service
To support this, we have strengthened our organisational approach through both a Vulnerability Strategy and, now, the publication of our vulnerability policy. The strategy sets out why vulnerability matters and how it underpins trust and access to justice. The policy defines the standards our people must follow every day.
At the heart of our approach are our CARE principles: clarity and understanding, accessibility and inclusion, reliability and trust, as well as empathy in action.
These are not abstract ideals – they guide how we communicate, how we design processes, and how we interact with those who come to us for help.
Supporting vulnerable customers is not a bolt-on. It is embedded in everything we do.
Practically, our policy is built around three questions developed by Dr Chris Fitch and the Money Advice Trust:
- vulnerable to what?
- supported how? and
- if not us, who?
Our people will focus on the specific risks an individual may face, the adjustments needed to support them, and where additional help may be required beyond our remit.
We also recognise that vulnerability is not always disclosed. That is why our staff are trained to identify indicators through interaction, supported by specialist, and excellent, organisations such as Surviving Economic Abuse and Refuge.
What we see in our casework
We are seeing expanded access to financial services, especially in pensions and investments – driving inclusion but also increasing exposure to harm.
Vulnerable customers are over-represented in higher risk investments, quasi-gambling trading behaviours and complex digital platforms that make it harder to pause, reflect or seek advice. And there are emerging risks in cryptoassets and finfluencer-led promotions.
The Consumer Duty is a positive intervention that is raising standards across the system. But we do still see cases where firms stepped in too late and missed signs that a customer might be struggling.
We also see the opposite – cases where firms step in too early, or make assumptions without fully understanding the customer’s situation, which can lead to frustration. The challenge is proportionate intervention – to support autonomy while preventing harm.
There is also genuinely excellent practice, and this is where the trajectory is a positive one for customers.
A growing number of firms are designing their services in ways that recognise vulnerability early and reduce harm. ‘Tell us once’ disclosure is a good example, where customers only have to share sensitive or traumatic information once rather than having to repeatedly recount distressing experiences to different people.
We’re also seeing accessibility features built in by default rather than treated as exceptions and clearer communications offered proactively. These changes don’t just help people who identify as vulnerable – they improve experience for everyone.
Performance and predictability
Importantly, performance and process are critical to addressing vulnerability. Prolonged uncertainty can have serious consequences for those already under strain. Timeliness and predictability are not administrative objectives but protections against harm.
That is why our transformation programme is focused on delivering a consistent, predictable and transparent service. Our ongoing reforms – supported by better use of technology, clearer processes and more effective triage – are designed to deliver faster resolution and clearer boundaries.
We are also transforming how we use technology, including artificial intelligence, responsibly and transparently. At the Financial Ombudsman Service, it supports human judgement. It does not replace it.
Ultimately, vulnerability is a shared system challenge. Trust in investment, advice and financial services, is not defined by when things go right, but by how the system responds when things go wrong.
Our insights exist not only to resolve disputes, but to help prevent harm. When we recognise vulnerability and design services that work for those at greatest risk of harm, we build a system that works better for everyone.