FCA Consumer Duty vs Vulnerable Customer Care: What Automotive Dealer Groups Need to Know

The FCA’s Consumer Duty and Vulnerable Customer Care frameworks share a common goal: delivering fair treatment and positive customer outcomes. While each has its own focus, there is significant overlap—especially within the automotive sector. For dealer groups, understanding this relationship is essential for achieving FCA compliance, building customer trust, and safeguarding long-term success.

What is FCA Consumer Duty?

The FCA’s Consumer Duty requires businesses to:

• Act in the best interests of all customers

• Provide fair, transparent, and jargon-free information

• Ensure products and services meet customer needs throughout the entire lifecycle

This is an outcomes-based regulation—dealerships are measured on the results customers experience, not just on process.

What is Vulnerable Customer Care?

Vulnerable Customer Care focuses on identifying and supporting customers who may be at greater risk of harm due to personal circumstances. These vulnerabilities can include:

• Health conditions

• Financial difficulties

• Cognitive or decision-making challenges

• Language or communication barriers

By recognising vulnerabilities early, dealerships can adapt their approach and ensure customers are supported fairly.

Where Consumer Duty and Vulnerable Customer Care Overlap

Both frameworks reinforce each other. Together, they create a stronger compliance and customer service culture:

1. Fair Treatment for All

• Consumer Duty: Every customer must receive fair and transparent treatment.

• Vulnerable Customer Care: Extra safeguards ensure vulnerable individuals are not disadvantaged.

Example: A customer with limited financial literacy may struggle to understand finance agreements. Consumer Duty ensures the terms are clear; Vulnerable Customer Care ensures further explanation and support are offered.

2. Outcomes-Based Accountability

• Consumer Duty: Products and services must deliver good customer outcomes.

• Vulnerable Customer Care: Tailoring support ensures positive results for those facing challenges.

Example: Offering payment flexibility for customers in financial hardship meets both obligations.

3. Proactive Identification of Needs

• Consumer Duty: Dealers must understand customer needs before recommending products.

• Vulnerable Customer Care: Goes further by spotting hidden vulnerabilities through training and observation.

Example: Staff noticing hesitation or stress during a sales discussion may pause the process to explore support needs.

4. Training and Awareness

• Consumer Duty: Employees must understand how to apply Duty principles.

• Vulnerable Customer Care: Staff must be equipped to spot and respond to vulnerabilities.

How Dealer Groups Can Deliver on Both

To ensure FCA compliance while building stronger customer relationships, dealer groups should:

• Embed a customer-first culture – treat compliance as a route to better experiences, not just a regulatory box-tick.

• Leverage compliance technology – use FCA compliance software to flag potential vulnerabilities and track outcomes.

• Tailor communication – provide clear explanations, alternative formats, and personalised support.

• Audit and monitor regularly – assess outcomes, review policies, and close compliance gaps.

• Encourage cross-team collaboration – align sales, compliance, and customer service for a seamless approach.

The Benefits of Aligning Consumer Duty and Vulnerable Customer Care

• Build customer trust and loyalty

• Avoid FCA enforcement action and penalties

• Differentiate your dealership through ethical practices

• Deliver measurable improvements in customer experience

How ComplianceTrak Supports FCA Compliance

At ComplianceTrak, we help dealer groups succeed by simplifying FCA compliance and embedding best practice.

• FCA Compliance Software: Automates compliance checks, reduces admin time, and provides real-time updates.

• Expert FCA Guidance: Our consultants provide audits, training, and tailored support.

• Appointed Representative Services: We act as your Principal Firm for Consumer Credit and General Insurance, handling regulatory responsibilities while you focus on sales and growth.

Take the Next Step Toward Compliance Success

Is your dealer group ready to strengthen compliance and deliver better customer outcomes?

Contact ComplianceTrak today to learn how we can help you implement FCA Consumer Duty and Vulnerable Customer Care strategies that drive long-term success.