As financial comms regulations around vulnerable people tighten, are you ready?

From email campaigns to online advertising, social media content to influencers, digital channels have become a mainstay of financial services marketing strategies.

But financial services companies are also some of the most regulated, particularly when it comes to how they market products.

To wit: here in the UK, earlier this year the Financial Conduct Authority (FCA) released new guidance on the use of memes, reels and gaming streams in the promotion of financial products, including more stringent rules for influencers. It warns that promoting non-FCA approved products could be a criminal offense.

Over the past year, many marketers will also have been getting to grips with the FCA’s new Consumer Duty, which has the primary aim of “setting a higher standard of consumer protection in financial services”. By now, all financial services companies that sell products directly to consumers should have applied the Duty to both existing and new products.

Understanding vulnerable consumers

A key focus of the Duty is ensuring that ‘consumer understanding’ is at the heart of all communications, particularly when it comes to vulnerable customers.

Put simply, if consumers are receiving information that they can’t read or understand, or which is presented in a confusing way, financial services firms could be breaching the rules.

Many people can have characteristics of vulnerability, as defined in the Duty, including poor health, disability, neurodiversity, anxiety, aging, or a mental health condition.

A conservative estimate suggests that four out of 10 people require digital communications to be accessible (due to a range of conditions, including sight and hearing impairments, reading or cognitive difficulties, fine motor difficulties which make it harder to control a mouse, or more general impairments associated with aging).

So, getting digital accessibility right is a must-have, not a nice-to-have. And since most customer communications are now in digital form (emails, texts, online customer service chat functions, PDF statements), all these need to be accessible to all customers.

Many firms already take digital accessibility seriously by following the Web Content Accessibility Guidelines (WCAG) – the technical standards for delivering accessibility in websites and apps. But if you want to make sure vulnerable people can your digital tools and services, you’ll have to go beyond WCAG. WCAG does a great job of capturing the needs of people with many disabilities, but it misses many of the things people who are neurodivergent, aging, or have mental health conditions need.

Let’s look at two specific and potentially vulnerable audiences: older consumers and neurodivergent people.

Older consumers’ needs

A recent report we at Hassell Inclusion published found that over-65s are a highly active online community, particularly when it comes to managing finances. 84% of those we surveyed said they conducted their banking online; nearly two thirds (60%) had bought an insurance policy.

However, 81% said they are frustrated by inaccessible websites and apps, while 70% say businesses fail to consider age-related impairments. Problems they experience include not remembering complicated passwords (37%), confusing site navigation (34%), not having enough time to complete a task before being ‘timed out’ (32%), and text being difficult to read (30%). More than one in ten (11%) said they found it difficult to hear the sound in online videos.

All of these things can bring increased levels of anxiety to the online experience.

Communicating with neurodivergent customers

For neurodivergent customers, the challenges are very different. Each person with a neurodiverse condition is unique. Their accessibility requirements are unique as well.

For example, people with autism can be task-focused, so if they can’t quickly find the information they’re looking for early on a page, they will leave. Similarly, too much information can also be overwhelming, as they can find it hard to filter out what is important and what isn’t. Imagery is also important. When visiting a banking website, you may see a picture of a happy family being used to advertise a mortgage or credit card, but very rarely the product itself. For those with autism, this kind of imagery just does not work.

To help companies understand how to design for these important audiences, we have worked with the National Autistic Society to research and develop a set of recommended guidelines.

Accessibility and vulnerability should work together

The key is to bring your accessibility and vulnerability experts together. People who are vulnerable may also have a disability and vice versa. So, linking vulnerability and accessibility will give financial services marketing teams a more complete picture across all communications, not just website and online platforms.

Read more on money, finance & utilities at our dedicated focus week hub.