The four drivers of vulnerability: what FCA guidance says to check
FG21/1 frames vulnerability through four drivers. Checking each — and recording the outcome — is the file-level work the guidance asks for.
What the FCA says: FG21/1 and the four drivers
FG21/1, the FCA's finalised guidance on the fair treatment of vulnerable customers, describes vulnerability through four drivers — health, life events, resilience, and capability — that can exist alongside each other and change over time. The guidance and the supporting material sit on the FCA's Consumer Duty pages, with the firm-level examples collected in the Consumer Duty publications library.
At file level the drivers are a check list, not a label. The record shows which drivers were considered, what was found, and what changed because of it — the outcome, not just the category.
The four drivers, at file level
Health
Physical or mental health conditions that affect the client's ability to engage with advice or manage finances.
Life events
Bereavement, divorce, loss of income — events that change circumstances and can reduce capacity to make decisions.
Resilience
Low financial resilience: limited savings, difficulty absorbing shocks, reliance on income that may be at risk.
Capability
Low knowledge or confidence in financial matters, or barriers like language or access. The client may need simpler communication.
Worked example: checking the drivers without a medical interview
A full check does not require clinical questions — it requires the drivers to be considered against what the client has told you. Anonymised and illustrative.
Before
Nothing recorded. The adviser “just knew” the client was fine — no drivers listed, no outcome, no reasoning.
After
“Drivers considered — health: no indicators; life events: bereavement in 2025, now settled; resilience: limited savings, flagged; capability: comfortable with written communication. Outcome — indicators present on resilience; adjustments made: review timeline extended and any recommendation checked against the capacity to absorb loss.”
Common mistakes when using the drivers
- The tick-box check. Four drivers listed with no finding and no reasoning — a checklist that records nothing.
- The label without the evidence. Writing “not vulnerable” without the characteristics that were considered.
- Disclosure as the only test. Assuming silence means no vulnerability; resilience and capability are often unspoken.
- The one-time check. Life events arrive between reviews; the drivers are re-checked when a trigger appears.
The four drivers at a glance
| Driver | File-level signals | The common gap |
|---|---|---|
| Health | Conditions that affect engagement or decisions. | Not considered, or treated as a medical question. |
| Life events | Bereavement, divorce, loss of income. | Checked once and never revisited. |
| Resilience | Limited savings, shocks, income at risk. | Missed — often unspoken and invisible. |
| Capability | Low confidence, language or access barriers. | No communication adjustment recorded. |
Related reads
The drivers are the foundation of the vulnerable customers hub. Pair them with the money-side indicator check list and the one-paragraph documentation wording to close the loop in the file.
Frequently asked questions
Do the four drivers cover everything?
They are the starting point FG21/1 gives firms for framing how vulnerability can arise, not the whole test. What matters is that each driver is considered for the client and the outcome is recorded.
Can a client be vulnerable without saying so?
Yes. Resilience and capability are often unspoken, and signs such as missed payments, arrears, bereavement, or third-party pressure are indicators to check for. The file records that they were checked.
Do I record the client's medical history?
No. The file records the characteristic considered and the outcome — not a medical history. The guidance asks for the consideration and the response, not clinical detail.
Your next step
Run the four drivers over your next suitability file and record each finding — the check, the outcome, the adjustments. Start a free trial or see pricing.