Consumer Duty demands more than waiting for disclosure
Nearly a quarter of UK workers say money worries are already affecting their performance at work, and one in five have taken sick leave because of financial stress, according to new research from the Building Societies Association (BSA).
For mortgage brokers heading into one of the busiest remortgage years on record, that data should land as a warning: some of the clients coming through the door for an affordability review may already be under more financial pressure than the paperwork shows.
The findings, published ahead of UK Savings Week, also show that 27% of UK adults have less than £1,000 in savings and 21% could not cover an unexpected £300 bill. Specialist customer vulnerability firm MorganAsh argues the numbers should prompt financial services firms, intermediaries included, to ask a harder question: would they actually recognise a client who was struggling, particularly one who has not said so themselves?
Andrew Gething, managing director of MorganAsh, said: "The BSA's findings show just how far the consequences of financial difficulty can extend beyond the pounds and pence. It can have a detrimental impact on a person's health, their confidence, their ability to work and ultimately, their ability to engage with financial services firms and make important decisions. The big question for these firms is: would they actually know if one of their customers was struggling?"
He added that vulnerability often goes unspoken because clients themselves may not recognise it: "Financial difficulty can be an important indicator that a customer's resilience is under pressure, but it may not be something that a customer is willing to disclose. Furthermore, customers may not consider themselves to be vulnerable, particularly if they are managing to cover their main commitments. Without that deeper understanding of the client's wider circumstances, a firm may not see any otherwise obvious signs of difficulty."
That gap matters more for brokers this year than most. Around 1.8 million fixed-rate mortgages are due to mature in 2026, on top of the 1.6 million that matured in 2025, meaning millions of affordability conversations with borrowers who took out their current deal at a very different rate. Consumer Duty already requires firms to identify and support customers in vulnerable circumstances, and the regulator has been explicit that reactive approaches — waiting for a client to raise a problem — fall short of what it expects.
Gething said Consumer Duty has sharpened that obligation rather than created it from scratch: "Consumer Duty has reinforced the importance of firms understanding their customers and delivering good outcomes, and effective identification and management of customer vulnerability is a critical part of that. The better firms become at recognising when someone may be struggling, the earlier they can step in with the right support, potentially preventing a difficult situation developing into a far more serious one, all while building trust and loyalty among their customer base."
For advisers, the practical implication sits inside the fact-find and beyond it. Routine questions about income and outgoings will not, on their own, catch a client who looks fine on paper but is exposed underneath. MorganAsh's own tool, the MorganAsh Resilience System, is one attempt to turn that judgement into a repeatable score rather than leaving it to adviser instinct. The broader lesson holds regardless of which system, if any, a firm uses: vulnerability needs to be built into the process, not left to whether a client happens to mention it.
The FCA has already signalled it is watching this space closely, recently tightening how firms must identify and report complaints involving vulnerable customers. For brokers, that raises the practical stakes of getting proactive identification right — not just as good client care, but as evidence they may need to produce if a case is ever queried.
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