How to identify vulnerable customers
proactively.

What proactive actually means

The FCA's Consumer Duty guidance uses the word "proactive" deliberately. It distinguishes between two fundamentally different approaches to vulnerability identification: reactive (identifying vulnerability when customers disclose it) and proactive (identifying vulnerability before customers disclose it, through the firm's own systems and processes).

Most firms operate reactively. Their vulnerability identification relies on: customers saying they are struggling, colleagues recognising distress signals in real time, or historical account data flagging a known vulnerability. These approaches are better than nothing — but they are not what Consumer Duty requires, and the FCA has made clear that reactive identification alone will not satisfy the evidencing requirement.

Proactive identification requires the firm to monitor interaction signals systematically and identify vulnerability regardless of whether the customer volunteers it. The question shifts from "did the customer tell us they were vulnerable?" to "did our systems identify that this customer may be vulnerable?"

The four drivers — and why they create an identification problem

The FCA's guidance identifies four drivers of vulnerability: Health (physical and mental health conditions), Life events (bereavement, job loss, relationship breakdown), Resilience (low financial resilience, over-indebtedness), and Capability (low financial literacy, language barriers, digital exclusion).

The identification problem is that vulnerability arising from any of these four drivers may not be visible from account data, customer profile, or even from what the customer says. A customer experiencing acute financial stress after redundancy may not mention it. A customer with mild cognitive impairment may not be aware of it. A customer in bereavement may be managing the interaction professionally while showing physiological distress signals beneath the surface.

This is why interaction-level analysis — monitoring the signals in real-time conversations rather than relying on profile data — is the appropriate approach to proactive identification. The interaction is where vulnerability manifests. The profile rarely reflects it accurately.

What adequate proactive identification looks like

Based on FCA guidance and enforcement activity, adequate proactive identification has four components:

Coverage: Vulnerability assessment must occur across all relevant interactions — not a sample. Standard QA reviews 2–3% of interactions. Proactive identification requires systematic coverage of 100% of interactions in regulated contexts, or a clearly evidenced risk-based approach to coverage that the FCA can interrogate.

Signal sources: The assessment must go beyond what customers say. Tone, speech pattern, interaction behaviour, and non-verbal signals (in video interactions) are all relevant vulnerability indicators. A firm that only assesses vulnerability based on customer statements has a coverage gap.

Documentation: Assessment must be recorded at the interaction level. The FCA expects to see: when vulnerability was assessed, what process was used, what signal was detected (or not detected), and what action followed. Assessment that happens but leaves no documentation is assessment that cannot be evidenced.

Outcomes monitoring: The firm must monitor whether vulnerable customers received appropriate treatment and whether outcomes were fair. This requires linking vulnerability identification to subsequent handling data.

The self-declaration trap

Many firms have invested in self-declaration mechanisms — asking customers directly whether they have any vulnerabilities, providing easy routes to disclose, training colleagues to ask sensitively. This is valuable and should continue. But it cannot be the primary identification mechanism for Consumer Duty purposes.

The customers most likely to need proactive identification are the customers least likely to self-declare. Customers in cognitive decline may not recognise their own impairment. Customers in acute financial distress may be ashamed or in denial. Customers in bereavement may be managing professionally but carrying significant emotional load. The FCA's requirement for proactive identification exists precisely because self-declaration fails for the most vulnerable.

Technology as the proactive identification layer

EchoDepth provides the interaction-level analysis layer that closes the proactive identification gap. For voice-based interactions, EchoDepth analyses speech rate, hesitation patterns, vocal pitch variation, and prosodic signals of cognitive load and emotional distress — producing vulnerability flags in real time without requiring the customer to disclose anything.

For video interactions, FACS facial analysis adds the involuntary physiological signal dimension — detecting Action Unit patterns associated with stress, suppressed distress, and cognitive load that colleagues cannot reliably observe in real time and that no self-report mechanism captures.

Each flagged interaction generates a timestamped record showing which signals were detected and at what severity. This produces the interaction-level documentation the FCA requires and the outcomes monitoring linkage that Consumer Duty mandates.