An image of the cover of the report. The design is white at the top, and colourful concentric circles at the bottom

Designing for Inclusion: Embedding Vulnerability into Financial Services Proposition Design

When nearly half the population lives with a vulnerability characteristic, why are so many products and services still treating vulnerability as the exception rather than the norm?

The FCA’s Review of Treatment of Customers in Vulnerable Circumstances found that “firms are yet to make significant progress in product and services design” and that “firms should consider this as a focus area as they continue to embed the Consumer Duty”.
As well as an opportunity to improve compliance, inclusive product and service design leads to better outcomes for more customers, and opportunities for stronger commercial performance.

Our new report, “Embedding Vulnerability into Proposition Design” provides a practical framework for embedding inclusion into every stage of proposition development. This blog explores the key insights from the report, with a particular focus on the Proposition Design Maturity Framework, a strategic tool to help you make progress, engage stakeholders, and deliver good outcomes for more customers.

From Labels to Impact: A New Lens on Vulnerability

We all recognise the four drivers of vulnerability, which have been helpful to support firms in understanding who may or may not be in vulnerable circumstances. While these categories are useful, they can lead to a checkbox mentality where firms focus on identifying, counting and responding, rather than designing systems that prevent harm in the first place.

That’s why our report proposes an impact-first approach. Instead of asking who is vulnerable, we encourage firms to explore the Impacts, Triggers and Resulting Harms from products and journeys. The report includes six examples as a starting point, but the model is designed to grow with your understanding. For firms ready to take a different view on vulnerability, this is a practical route to move from reaction to prevention, designing out harm from the very start.

This shift in mindset can also reframe vulnerability as a design challenge – and opportunity – not a customer deficit. It encourages firms to build inclusive systems that work better for everyone, regardless of their circumstances.

Five icons in a circle, looking like a lifecycle. The icons are Orange with a lightblub for Discover Dark blue with a magnifying glass for Define Red with a cube for Design Green with the cube being shipped for Deliver Purple with a magnifying glass for Detect The centre says "the proposition lifecycle"
The Proposition Lifecycle: Designing for Inclusion from the Start

The report outlines five key stages in the proposition lifecycle:

  • Discover – Understand the full range of customer needs, especially those often overlooked and with complex or unpredictable needs

  • Define – Set clear, measurable outcomes for all customer segments, and validate these with different groups

  • Design – Embed inclusive design principles from the outset, designing with customers at each stage

  • Deliver – Ensure ease of access and understanding across all channels, with well designed journeys, communications and front line support

  • Detect – Monitor real-world outcomes and iterate based on evidence

Each of the stages, and associated activities, are explored in more detail in the report. While these stages provide a practical roadmap, the real power lies in how firms mature their approach over time. That’s where the Proposition Design Maturity Framework comes in.

The Proposition Design Maturity Framework: A Roadmap for Progress

The Maturity Framework that we have developed helps firms assess where they are today and chart a path toward more inclusive, equitable proposition design. It’s not a linear checklist, but a flexible tool that supports continuous improvement across five levels of maturity:

  • Awareness – At this stage, firms are just beginning their journey. They may recognise the importance of vulnerability but haven’t yet embedded it into their processes

  • Foundations – Firms may have frameworks and policies in place but they’re inconsistently applied

  • Embedding  – firms are now designing with customer vulnerability in mind, and early in the propositions process

  • Leading – customer inclusion is part of proposition DNA and business strategy
  • Pioneering – Firms are building products and systems that are equitable by design
The image is split into two sections. Left Section (Orange Box): Vertical text: "Awareness (Reactive)" Horizontal text: "We know it matters but we're not doing it yet" Below the text is an icon of a light bulb above an open hand. Right Section (Titled "Actions"): A list of five bullet points, each with a checkbox: Ensure good customer outcomes are defined for core stages of the journey at a high level Deliver basic training on Regulation and Guidance to ensure teams are aware of vulnerability as part of Consumer Duty requirements Audit current product development process for customer vulnerability awareness and touchpoints Review recent complaints and feedback for signs of exclusion and harm Start a cross-functional conversation about needs of customers in vulnerable circumstances

An example from the maturity framework, showing the Awareness stage

Using the Framework for change

The Maturity Framework is more than a diagnostic tool, it’s a strategic enabler. It helps firms:

  • Align with regulatory expectations, particularly under the FCA’s Consumer Duty.

  • Reduce risk by identifying and addressing harm before it occurs

  • Improve customer outcomes through better design and delivery.
  • Drive innovation by using diverse needs as a source of insight

  • Engage stakeholders internally to show benchmarking and roadmap for change

Importantly, the framework recognises that no firm is perfect. Most will be at different stages across different areas. What matters is the direction of travel, toward a culture that centres on customer outcomes and continuous improvement.

Designing for and with customers in vulnerable circumstances: A Competitive Advantage

Designing for vulnerability isn’t just about compliance, it’s about creating better products and better customer outcomes. Firms that lead in this space are not only meeting regulatory requirements; they’re setting new standards for what good looks like, and working towards a more equitable system for all customers.
By embedding inclusive design principles early and intentionally, financial services firms can future-proof their offerings, differentiate themselves in the market, and – most importantly – deliver fair, effective outcomes for all customers.

At Inclusive Outcomes, part of the Big Window Group, we help firms at every stage of maturity with a range of activities. Speak to us about:

  • Understanding the needs of customers in vulnerable circumstances, and where they may be susceptible to harm with your propositions and journeys
  • Defining and validating good outcomes with customers, including prioritisation of outcomes and what’s specifically important to customers in vulnerable circumstances
  • Inclusive Design for propositions and journeys, including our quick-fire discovery > design > prototype > iterate to propositions development
  • Customer journey mapping and communications testing for customers in vulnerable circumstances
  • Strategic review of your vulnerability strategy and approach, and how this aligns with peers in your sector
Download our report – Designing for Inclusion From Start to Finish
Find out about Lauren Peel
Lauren Peel

Lauren is a leader in consumer and financial vulnerability with over a decade of experience in consumer strategy and delivery, from insights and co-design through to experience and propositions.