Barriers to disclosure

What does disclosure mean and how can it help vulnerable customers?

Michael Reed-Smith

Enhanced Services Director

08 Jan 2025

Research & insights

If a customer informs a financial services provider of their personal circumstances, relevant additional support can be provided. But for many people there are significant barriers to them sharing this information with their provider. At any time around half of society could be experiencing personal challenges that affect their finances or their ability to make financial decisions, so it’s important to recognise and overcome barriers to disclosure so that tailored assistance can be provided.

We believe that by fostering trust, normalising disclosure, and offering tailored, empathetic support, financial service providers can significantly improve outcomes for customers in vulnerable circumstances. Collaborative efforts, like those led by Phoenix Group and Cowry Consulting, demonstrate the power of industry-wide initiatives to drive meaningful change.

Together, these actions can create a safer, more supportive environment for all.

Read Our Report

Why is it important to remove barriers to disclosure for vulnerable customers?

The FCA’s Consumer Duty places a requirement on firms to understand their customers’ needs and to have the flexibility to support them and deliver good outcomes. This includes the need to understand and take account of behavioural biases and the impact characteristics of vulnerability can have on customer needs and decisions.

Vulnerability is a complex issue and with varied causes. It can be temporary or permanent, but becoming vulnerable can affect every part of an individual’s well-being and it can have a short-term and long-term effect on people’s financial stability.

Vulnerability can cover many things, and often a customer who is considered vulnerable might not think to label themselves as such. This can be one reason why customers might not tell us that they are in a vulnerable position. If we know a customer is facing vulnerability, there are things we can do to help and support. But we need the customer to tell us they are facing vulnerable circumstances, and that’s why it’s so important to help remove barriers to disclosure.

What can we do to help remove barriers to disclosure?

The research highlights the following key areas for financial service providers to consider when supporting vulnerable customers.

Customers lack an understanding of what disclosure means within the context of financial providers or how to go about informing them.
Customers put off sharing information about needs, often leaving it until the emotional burden becomes too much.
Customers aren’t optimistic about the support they’ll receive or worry it will negatively impact them.
Customers with additional needs feel uncertain about their ability or may face challenges in communicating their circumstances effectively, often requiring the human touch to better support them.
Customers don’t fully trust that their financial provider has their best interests at heart.

How can this report help?

The report highlights the key stages of a disclosure journey along with demographic differences for each stage and an effective communication checklist. By addressing these areas, financial service providers can strengthen their relationships with customers, reduce barriers to disclosure, and ultimately deliver better support for those in need.

Read Our Report