A new industry report from the Equity Release Council has called on the later life lending sector to embed greater consistency in its approach to customer vulnerability, recognising both the strong progress already made and the need for practical support in more complex scenarios.
Published today in partnership with consultancy Inclusive Outcomes, the review — Later Life Lending and Customer Vulnerability — sets out current good practice, strategic priorities and case studies designed to help advisers and lenders support older borrowers more effectively.
With almost half of UK adults exhibiting at least one characteristic of vulnerability, according to the Financial Conduct Authority, the report argues that the sector must go beyond compliance with Consumer Duty and embrace vulnerability as a core component of advice, product design and customer service.
Among the areas of strength already identified across the market are structured fact-finding processes that allow for early identification of customers in vulnerable circumstances, tailored training programmes for advisers and staff, the appointment of dedicated vulnerability champions, and clear governance routes for handling complex or sensitive cases.
AREAS FOR IMPROVEMENT
The report also points to opportunities for further improvement, particularly in tracking and evidencing customer outcomes, adapting journeys to reflect diverse needs, and sharing data across the advice and lending chain to improve consistency.
To support these goals, the Council will launch a new practitioner toolkit, Safe Steps, in November. Designed to help firms embed vulnerability best practice across the distribution chain, the toolkit will include structured guidance on specific circumstances, adviser prompts, and real-life examples.
“we must move beyond compliance to deliver thoughtful, tailored support that reflects the lived experience of customers”
Lauren Peel, senior partner at Inclusive Outcomes, said the report reflected the strong foundation already laid by the sector, but that more needed to be done to ensure vulnerable customers receive truly tailored support.
“The Financial Conduct Authority believes that almost half of UK adults has at least one characteristic of vulnerability so it is vital that sectors and organisations really consider how they can best support their customers,” she said.
“Today’s report recognises the leadership already being shown across the later life lending sector, while offering practical ways to deepen that work. The Consumer Duty has set the benchmark — now we must move beyond compliance to deliver thoughtful, tailored support that reflects the lived experience of customers.”
SUPPORT GAP
Kelly Melville-Kelly, director of risk, policy and compliance at the Equity Release Council, said the forthcoming Safe Steps guidance would address a current gap in operational support.
“The sector has matured significantly in its approach to vulnerability — but the next phase must be about embedding consistency and driving continuous improvement,” she said.
“We know that individuals and organisations want to do the right things but at the moment, there is often a lack of practical, expert guidance to support complex interactions. Safe Steps, launching in November 2025, is designed to fill that gap and give advisers and lenders the tools to turn good intentions into confident, informed action.”
The Equity Release Council said the toolkit would draw on its guiding principle that customers engaging with member firms should receive trusted, tailored, transparent and thorough support throughout their journey.
