Identifying & Supporting Vulnerable Customers in the Automotive Showroom

Best Practice Guidance for Car Dealerships Under FCA Consumer Duty

Supporting vulnerable customers within automotive dealerships is both an ethical responsibility and a regulatory expectation. With the FCA placing greater focus on Consumer Duty and the fair treatment of customers, dealerships must be able to identify vulnerability, respond appropriately, and evidence the support provided throughout the entire sales and finance journey. Supporting vulnerable customers in the automotive showroom requires awareness, empathy, and a structured approach aligned with FCA Consumer Duty expectations.

This article outlines what constitutes vulnerability in the automotive showroom environment, how to recognise key indicators during customer interactions, and how digital tools can support consistent and compliant outcomes.

What Is a Vulnerable Customer?

The FCA defines a vulnerable customer as someone who, due to personal circumstances, is especially susceptible to harm. This harm is more likely to occur if businesses do not act with an appropriate level of care.

In a dealership setting, vulnerability can be temporary or ongoing, and may influence a customer’s ability to:

• Understand motor finance repayment implications

• Compare GAP, warranty, or insurance products

• Make confident and informed choices

• Communicate clearly or raise concerns

• Consider affordability and future financial impact

It is essential to recognise that vulnerability may not always be obvious. Sales teams must be able to identify signs through conversation, behaviour, and context.

Why Vulnerability Matters for FCA Compliance

The FCA expects dealerships to:

• Identify vulnerable customers at any stage of the journey

• Provide tailored, appropriate support

• Prevent foreseeable customer harm

• Deliver clear, balanced explanations of products and finance options

• Keep accurate documentation and evidence of support

Failure to do so may lead to:

• Customer harm or financial detriment

• Increased complaints and mis-selling allegations

• Damage to dealership brand reputation

• Regulatory scrutiny or enforcement under Consumer Duty

Supporting vulnerable customers is therefore a core compliance requirement, not an optional process.

Common Indicators of Vulnerable Customers in the Automotive Showroom

Not all customers will openly disclose vulnerability. Many signs may be subtle.

Financial Vulnerability

• Difficulty discussing affordability or budgeting

• Recent unemployment or reduced income

• Concern or anxiety around credit checks or repayments

Health-Related Vulnerability

• Difficulty concentrating or processing information

• Visible distress when reviewing documents

• Cognitive challenges or memory difficulty

Life Events

• Recent bereavement

• Divorce or separation

• Caring responsibilities or unexpected life stress

Low Confidence or Limited Experience

• First-time finance applicants

• Language or reading barriers

• Reliance on others to interpret product information

Recognising these signals helps ensure the dealership provides appropriate and fair customer support.

Best Practices for Supporting Vulnerable Customers

Once vulnerability is identified or suspected:

1. Adjust the pace of the conversation.

2. Use clear, plain language and avoid financial jargon.

3. Check for understanding by asking open-ended questions.

4. Offer additional support, such as inviting a trusted third party to assist.

5. Record what was observed and what adjustments were made.

This documentation is essential for auditability and demonstrating fair outcomes

How Technology Can Support Dealerships in Managing Vulnerability

Digital tools can ensure vulnerability is managed consistently, objectively, and transparently.

InsightTrak

Designed to help dealerships identify, assess, and record vulnerability, InsightTrak provides guided prompts and support workflows to ensure that customers receive appropriate care and that the dealership can evidence its decisions.

ComplianceTrak Customer Journey

Ensures the entire vehicle, finance and insurance sales process is structured, transparent, and compliant, reducing the risk of misunderstanding or miscommunication.

OnTrak Training Platform

Delivers ongoing compliance and soft-skills development, helping staff confidently recognise vulnerability and respond appropriately.

Together, these platforms support dealerships in delivering fair customer outcomes while meeting FCA expectations.

Benefits of a Proactive Vulnerability Strategy

Dealerships that build vulnerability awareness into their processes and culture benefit from:

• Increased customer trust and loyalty

• Reduced regulatory and complaint risk

• Improved staff confidence and communication skills

• Stronger audit trails and compliance assurance

Supporting vulnerable customers results in better experiences, reduced harm, and stronger long-term customer relationships.

Next Steps for Dealerships

To strengthen your approach to vulnerability:

• Review your dealership’s vulnerability policy and procedures

• Ensure all customer-facing teams receive ongoing training

• Implement structured documentation and evidence-gathering

• Consider digital assessment tools to support consistency and auditability

To learn how InsightTrak, ComplianceTrak, and OnTrak can support your dealership with vulnerability identification, compliance, and training, contact us to arrange a demonstration.

→ Contact our team to schedule a discovery session.

Frequently Asked Questions

What counts as a vulnerable customer in a dealership?

Any customer whose circumstances may affect their ability to understand or manage the vehicle purchase, finance or insurance decision-making process.

Is identifying vulnerable customers an FCA requirement?

Yes — under Consumer Duty, firms must take extra care with customers who may be at higher risk of harm.

How should vulnerability support be recorded?

Dealerships must document indicators, decisions, and support steps taken. InsightTrak allows this to be done consistently and securely.

Can technology help recognise vulnerability earlier?

Yes. Digital tools like InsightTrak provide structured vulnerability assessments, prompt staff to ask the right questions, and guide them on how to respond appropriately. This ensures customers receive fair support and that the dealership can demonstrate compliance.