FR: Firstly, can you tell us a little bit about MorganAsh?
MorganAsh is a support services provider specialising in customer vulnerability. We work with firms across the financial services and utilities sectors to enable them to better understand and monitor vulnerable customers and deliver good outcomes – as required by Consumer Duty. We do this primarily through the MorganAsh Resilience System – or MARS – which is our digital platform that combines consistent and objective assessment with live recommendations and tracking of support needs, detailed reporting and full benchmarking against both peers and FCA standards.
We also provide a range of services including medical underwriting, tele-interviewing and protection new business and claims reviews, working with leading insurers across the UK and Ireland. So while some may know us for our work around Consumer Duty, we’ve been working with industry to improve costumer outcomes for well over 20 years.
FR: As we begin 2026, how would you rate the progress of financial services in embedding the principles of Consumer Duty?
Consumer Duty has placed fresh emphasis on good outcomes for vulnerable customers and encouraged plenty of conversation across financial services. It’s fair to say though that progress in adopting and embedding these principles has been slow. There’s still some complacency in the market too and a sense that many firms are yet to really understand how Consumer Duty has expanded the scope of customer vulnerability and risen the bar in what is expected of firms. In truth, customer vulnerability was low on the to-do list for firms initially, with much of focus on Consumer Duty being on fair value. However, firms have realised that customer vulnerability is the hardest part of the Duty, and so are now only just getting to grips with it.
On the ground, we have seen firms that have really embraced Consumer Duty and understood the value of staying closer to clients, improving service and support, and delivering better outcomes. We have seen firsthand that firms are unlocking the competitive advantage that the regulation offers, as well as the commercial benefits of leveraging vulnerability understanding to launch new, highly-targeted products. There’s no doubt that much of the focus of Consumer Duty has been on the stick rather than the carrot, and that hasn’t helped. However, there are real world examples out there of firms benefitting greatly from the new regulation.
FR: What has been the stumbling block?
There are clearly still firms struggling with the transition from more prescriptive, tick-box regulation to a principles-based approach. Along with this, there are sizeable knowledge and skills gaps – particularly around customer vulnerability. Fundamentally, so many firms just don’t know who their vulnerable customers are – let alone what outcomes they are receiving. This is compounded by a lack of investment in technology and processes to not just bridge those gaps, but to drive efficiencies and generate the robust data and intelligence needed.
Part of the issue has been a reactive approach adopted by many firms – either waiting for customers to share their vulnerabilities, or focusing on a subset of customers – or a single channel, like claims or complaints. This is an important place to start but doesn’t give the full picture. It would be like looking for people with blonde hair at a football match, but only looking in the away stand. Given the scope of vulnerability, we need to look much broader and understand the challenges facing all of our clients.
FR: How can firms improve?
Gaps in knowledge and skills have long been identified as an issue, most notably by the Chartered Insurance Institute (CII) It has also identified that understanding customer vulnerability is the hardest part of Consumer Duty – something that the FCA makes no secret of and why it has long advocated for technology adoption.
Towards the end of last year, the CII published new guidance for firms on what ‘good’ looks like when it comes to supporting vulnerable customers, and it’s a real step forward. It gives firms a comprehensive specification to meet the principles of Consumer Duty and turn this into practical action. Crucially, it also focuses on the necessary IT systems, processes and data infrastructure for firms to identify, classify, monitor, support and report on both customer vulnerabilities and consumer outcomes. Given that this guidance has now become the de facto standard for the Financial Ombudsman Service, it would be wise for firms to take the learnings from this guidance to not just streamline, but shore up their processes and overall approach.
FR: What are your expectations for customer vulnerability in 2026?
There’s absolutely no question that vulnerability will remain a pressing issue in 2026 and a top priority for all firms across financial services. While many firms have introduced manual training approaches there is now a realisation that this is expensive, and almost impossible to deliver consistent data for monitoring and reporting. Digital solutions deliver efficiency, scale and hence are coming into favour.
You only have to look at continued economic uncertainty, ongoing challenges in the labour market and pressures around arrears to know that many consumers run the risk of falling into difficulty.
Providing support is totally reliant on firms knowing who their vulnerable customers are, so the recommendation would be to invest in customer vulnerability management – put the necessary technology and infrastructure in place to not just deliver a good outcome, but to attract new business, retain customers and unlock new opportunities presented by knowing customers better.
