Typically when presented with the phrase 'vulnerable consumer' we may think of someone with learning difficulties, a disability, someone very young, or very old. These heuristics are accurate in practical terms, however, for a broader understanding of the concept we should recognise that anyone can become vulnerable at any point.

Experiencing loss in life, bereavement, accident, illness, redundancy or failed relationships can all make someone vulnerable. A vulnerable consumer, under all definitions, is recognized as someone who is at risk of being exploited or cannot fully understand/make the best decisions for themselves. Undergoing a major life event could make us prone to spending unreasonable amounts of money on products or services that are not right for us at the time.


'John recently underwent a divorce, he just leased a new BMW, can he really afford it?'

'Martin has a learning disability and limited understanding of the internet - he should watch he doesn't get scammed'

'Jane lost a parent recently, she was left a substancial sum of money - I hope she doesn't make any big decisions whilst grieving'

'Sara has limited mobility, she relies on online shopping - I hope she knows to look for the best deals'

'Kate is purchasing a car to escape abuse, she has limited exposure to the motor trade, she should be careful she is not taken advantage of'


In recognition of this concept, various organisations have published guidance on consumer vulnerability, how to best manage, identify and understand the idea.

The Financial Conduct Authority (FCA) has principles of consumer vulnerability which include things such as; understanding consumer needs and monitoring and assessing their own performance when dealing with vulnerable consumers.

The International Organization for Standardisation has published ISO22458:2022 - Consumer Vulnerability, a standard which companies can adopt, ensuring that all considerations are in place for meeting the requirements of vulnerable consumers. The standard is comprehensive and mentions the topic of inclusive design - a main focus point for businesses considering vulnerable consumers.

Debt Collection Agencies and Vulnerable Consumers

In the UK, debt collection agencies must be authorised by the Financial Conduct Authority. As the agenda of the FCA angles in encouraging regulated businesses to adopt good practice in dealing with vulnerable consumers; debt collection agencies and similar financial firms are coming under increased pressure to adopt procedures and policies for vulnerable consumers. The CSA (Credit Services Association), a body which many debt collection companies are a part of - has a code of practice which provides guidance on dealing with vulnerable consumers. Greenkite also recognizes the concept and has published a blog with plenty of guidance on the matter.

Any company which chooses to adopt ISO 22458 will also influence other companies to which they sell or subcontract debt to; as a very specific requirement within ISO 22458 stipulates that 'if debt is subcontracted or sold the organisation shall ensure that the debt collection agency follows the requirements of the standard'.

This creates a complicated situation for bailiff companies to which have acquired and seek repayment for debt - the standard cuts lots of slack for vulnerable consumers who are in debt by encouraging techniques such as repayment plans/waiving debt etc. This of course goes against the very nature and sole purpose of a debt collection agency!

We'll leave that one for the universe to figure out.
For companies that seek recognition for their vulnerable consumer management - there are very few providers.

ISO Assured offers certification to ISO 22458:2022, along with the resources needed to fully understand and implement the standard. Certification can help you get the recognition you deserve in efforts towards providing positive outcomes and an inclusive service for vulnerable consumers.

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