The Chartered Insurance Institute (CII) has launched a new vulnerability initiative with Three Hands Insight and four Chartered insurance firms.
The CII has sponsored their participation so they can combine their customer outcomes expertise with insights from charities and people with lived experience of vulnerability, with the aim of developing fresh guidance and examples of good practice for the wider market.
Building on Consumer Duty and vulnerability work
The partnership builds directly on the CII’s Road to Consumer Trust campaign, which has been supporting firms with the practical implementation of the Consumer Duty, with a particular focus on vulnerability management.
Vulnerability remains a key regulatory priority. The Financial Conduct Authority’s (FCA) guidance on the fair treatment of vulnerable customers, FG21/1, sets expectations that outcomes for vulnerable customers should be at least as good as for other customers, and that firms must understand the nature and scale of vulnerability in their customer base, train staff appropriately, adapt products and communications, and monitor outcomes.
Against that backdrop, the CII’s latest initiative is aimed at helping insurers turn regulatory expectations into detailed operational changes, particularly around how they design, communicate and deliver products for customers in complex circumstances.
Lived experience at the heart of the project
Working with Three Hands Insight, participating firms will engage directly with members of a Three Hands Lived Expert Research Community, who will represent a range of vulnerabilities including ill health, physical disability, dementia, visual impairments, neurodiversity and unpaid caring responsibilities.
Three Hands Insight’s community includes people from across the UK with characteristics such as physical and non‑visible disabilities, neurodiversity, poor mental health, low or erratic income, low financial confidence and major life events such as bereavement. The consultancy uses immersive insight sessions, inclusive design panels and ethnographic projects to bring those experiences into product and service design work with financial services clients.
For the CII project, focus areas will include how vulnerability is identified and disclosed, what vulnerable customers experience during the claims journey, and how and where financial exclusion arises. The work will involve practical exercises such as feedback from participants on paper and digital communications, and discussion of cases where individuals have been unable to obtain insurance because of their circumstances and the impact this has had on their lives.
“This project with the CII and leading insurance businesses is a brilliant opportunity to improve outcomes for vulnerable customers across the UK," said Michael Hilton, director at Three Hands Insight. "We know how powerful it is to learn directly from those with lived experience so we are thrilled to bring our immersive insight approach to the insurance sector.”
Rising expectations under the Consumer Duty
Allianz, Chubb, Cornish Mutual and Covéa are all subject to heightened expectations under the Consumer Duty, with boards required to sign off annual assessments of customer outcomes, including outcomes for those in vulnerable circumstances.
The FCA has emphasised that vulnerability can arise from health conditions, life events, low resilience or low capability, and that many customers will experience multiple, overlapping vulnerabilities. Recent regulatory reviews have highlighted particular weaknesses around identifying vulnerability in digital journeys, tailoring communications and using management information to track outcomes, increasing pressure on firms to demonstrate tangible improvements rather than relying on high‑level policies.
Alongside the new initiative, the CII is running specialist “Vulnerable Customers” training workshops aimed at staff responsible for implementing vulnerability frameworks, covering strategies to identify and support vulnerable customers while meeting regulatory expectations on outcomes.
New standards and tools for the profession
The CII said this collaboration with Three Hands Insight is the first in a series of societal initiatives it plans to deliver with Chartered firms, designed to create new standards, tools and resources for the profession on issues such as vulnerability, financial inclusion and accessibility.
Outputs from the project, expected to include practical guidance, case studies and examples of good practice drawn from the lived‑experience research, are intended to be shared more widely across the market.
For insurers and intermediaries, they are likely to provide additional reference points as the FCA continues to focus on how firms evidence good outcomes for customers in vulnerable circumstances, rather than simply having policies in place.
