I’m pretty certain that any financial planner would define my mum as ‘vulnerable’. 

She’s in her seventies. She has relatively low financial literacy, exacerbated by the cognitive decline linked to her multiple sclerosis. She also has a chronic form of leukaemia, which means she’s going to be on chemo for the rest of her life. She loves getting out once a day, whether to art class, choir, pilates or sound therapy. But other than that, most of her time is spent at home, and much of that is spent on her iPad (unless she’s out joyriding on her mobility scooter with my son).

That’s how we talk. A quick 5 minute video call for her to see her grandson every evening, or voice notes to arrange the next weekend meetup. It’s how she reads the news, keeps up with friends, manages her appointments, and stays connected to a world that her physical conditions have made physically harder to reach.

The iPad isn’t a concession to her circumstances. For her, it’s her independence.

I’m sharing this now because I’ve realised how often I use her as an example (with her blessing, I might add) whenever I hear the assumption that comes up, almost without fail, in conversations about vulnerable clients and digital portals.

The assumption always seems to be that if a client is categorised as ‘vulnerable’ (or elderly) then, by definition, the right response is to route them toward a human and away from technology. It’s a well-intentioned assumption – and in many cases ends up being the right response. But I’d like to challenge the idea that it’s the only response.

As firms embed Consumer Duty into their new business processes, the treatment of vulnerable clients has moved from a compliance footnote to a board-level concern. The FCA’s own review findings make clear that communication channels are failing vulnerable clients across the board – not just digital ones.

The question isn’t whether digital is appropriate for these clients. It’s whether firms are designing digital experiences that are actually worthy of them. So who better to bounce my ideas off than Sim Sangha from Moneyinfo (arguably the gold standard of wealth management digital portals), and I was comforted to know that he shared some of my views.

“There’s still a tendency in wealth management to see digital tools and vulnerability as being at odds with each other. I think that misses the point. The right portal should make it easier for clients to disclose and access sensitive information, feel in control and get support when they need it. That’s good for clients, good for advisers and good for Consumer Duty. A low-cost way to deliver high impact in a number of areas.”

Sim Sangha, Founder and Business Development Director, Moneyinfo

First, let’s reframe what vulnerability actually means

The FCA identifies four drivers of vulnerability: health, life events, resilience, and capability. In a wealth management context, these don’t always look the way you might assume.

Health vulnerability isn’t just clients in obvious crisis. It includes a high net worth client in their late seventies with early-stage cognitive decline – still engaged, still opinionated, but increasingly susceptible to confusion, fatigue, and influence. It includes the high-earning professional whose severe anxiety disorder makes every market movement feel catastrophic.

Life events create a distinct type of vulnerability that is often temporary but acute. A recently widowed spouse who has never managed household finances, now holding a significant investment portfolio they don’t understand. A client mid-divorce, financially exposed and emotionally compromised. An entrepreneur who has just sold their business and is sitting on more liquid capital than they’ve ever navigated. Each of these clients is engaged and capable in normal circumstances, yet suddenly – and perhaps temporarily – they’re not.

Low resilience is perhaps the most underestimated driver in wealth management. These are clients who are financially comfortable but emotionally fragile when it comes to money. They panic-sell during corrections. They ring the adviser three times a day during a volatile week. They make impulsive decisions driven by financial media rather than their plan. Wealth and resilience are not the same thing.

And capability – the ability to understand financial products, structures, and decisions – is frequently overlooked in high net worth client bases. The self-made entrepreneur who built a £10m business from scratch may have almost no working knowledge of tax wrappers, asset allocation, or estate planning. Inherited wealth recipients may never have made an active financial decision in their lives. Neither will readily admit it.

The critical point is this: any client can move into vulnerability at any time, and many of your clients are exhibiting characteristics of it right now without either party necessarily acknowledging it.

Why digital is not the problem – and might be the solution

Here’s what a poorly designed portal does for a vulnerable client: it’s hard to get into to begin with, and then presents dense menus, assumes financial literacy, offers no escalation path, and leaves them feeling more confused than when they arrived. That’s a real problem – but it’s a design problem, not a technology problem.

Here’s what a thoughtfully designed portal can do for the same client: it’s completely secure, easy to set up, and then gives them a single, consistent, always-available view of their financial world. It doesn’t forget. It doesn’t get impatient. It doesn’t require them to perform composure during a difficult phone call. It creates a written record of every interaction. It lets them read, re-read, and absorb information at their own pace, at any time of day or night.

For clients with health-related vulnerability, this is particularly significant. A client with early cognitive decline is often better served by a clear, consistent digital interface than by a phone call with no record. For a client with anxiety, the ability to check a portfolio position at 2am – without needing to wait for a callback – can genuinely reduce distress rather than amplify it.

The portal doesn’t replace the human relationship. But it can make the human relationship more effective by removing the friction, confusion, and inaccessibility that currently surrounds it.

“Simple client facing technology does not remove the human element, it strengthens it. A well-designed portal gives advisers a better platform for more timely, better-informed conversations, while giving clients a clearer and more consistent experience in between those moments. It also helps both parties get through the paperwork quicker, particularly when action relies on approvals, sign-off or disclosure of further information.”

Sim Sangha, Founder and Business Development Director, Moneyinfo

Four ideas that go beyond accessibility compliance

Most wealth management firms approaching this topic start with things like font sizes, screen reader compatibility, colour contrast ratios. These matter. But they are the floor, not the ceiling.

1. Trusted companion access

Give clients the ability to designate a trusted third party – not a Power of Attorney, just someone they trust – with view-only access to the portal. A spouse. An adult child. A close friend. This is me for my parents’ execution-only ISAs and SIPPs, by the way.

This is not about removing client autonomy; it’s about creating a support structure around it. For clients with health or life event vulnerability, knowing that someone they trust can see the same picture can be genuinely reassuring. It also creates a natural early-warning mechanism: a trusted companion who notices that statements aren’t being opened or that portfolio values have shifted significantly is far better placed to flag a concern than a firm that only interacts quarterly.

2. Client-initiated support flagging

Rather than relying on advisers to identify and log vulnerability – a process that is inconsistent, uncomfortable, and dependent on the quality of individual relationships – give clients a discreet, dignified way to flag that they’d like a little more support right now, perhaps broken down into different areas or topics, and presented however you see fit – whether simple tickboxes, slide bars or free text boxes.

No label. No category. Just a quiet signal that adjusts the firm’s behaviour: more frequent check-ins, simplified communications, a flag on the adviser dashboard, et cetera.

This inverts the power dynamic in a way that matters. The client isn’t being identified as vulnerable by the firm. They’re simply asking for what they need.

3. Behavioural pacing for high-stakes decisions

For clients with low resilience, the most dangerous moment is the intersection of a market event and an impulsive decision. A portal that makes it trivially easy to submit a large disinvestment instruction at the height of a news-driven panic is not serving that client well – even if it’s technically efficient.

Whether fully discretionary, advised, or execution-only – not to mention operational factors like fund cut-off times and anti-money laundering requirements – I realise there are complexities with this idea… but why not consider building in a 24-hour hold on large transactions above a client-configured threshold, with a prompt to speak to an adviser before the instruction is executed. The digital equivalent of an adviser saying “let’s talk about this before we do anything.”

4. Explainability as a core feature

Low capability clients don’t know what they don’t know. They won’t ask for a glossary. They won’t flag that the performance report is confusing. They might even nod along in the annual review meeting and leave no clearer than when they arrived.

A portal built for this client might show fees in cash terms, not just basis points. It might have a tooltip explaining what an ISA allowance actually means for them, not in technical terms but in outcome terms. It could surface a “what does this mean for me?” layer beneath the data. And critically – it could track engagement. A client who has never opened a document, never clicked on a piece of educational content, and never logged in except when prompted is telling you something important. That signal should reach the adviser.

What this means for Consumer Duty

The four Consumer Duty outcomes – products and services, price and value, consumer understanding, and consumer support – all have a digital dimension that many firms are only just beginning to explore.

“From my experience, the firms getting this right are the ones treating the portal as part of their Consumer Duty framework, not just a reluctant administration layer. Done well, it becomes a practical way to improve understanding and spot when extra support may be needed. For example, how frequently a client may be logging in or which screens they view the most can identify concerns bubbling away in the background that you wouldn’t otherwise know until the review. It simply delivers a more connected service across the client journey.”

Sim Sangha, Founder and Business Development Director, Moneyinfo

Consumer understanding is where I think the portal has the most untapped potential for vulnerable clients. A compliance-driven approach generates disclosures. A genuinely client-centred approach builds comprehension. These are not the same thing, and for clients with capability or resilience vulnerability, the gap between them is where the real harm lives.

Consumer support, meanwhile, should not be delivered despite the portal – it should be delivered through it. Embedded messaging, contextual escalation to human advice, and behavioural monitoring that surfaces clients who need proactive contact are all features that a well-designed portal can provide and a phone-first model structurally cannot.

But yes, I do firmly believe you should still also be able to have a ‘call your adviser’ button that they can click if that’s what they want to do. After all, there’s nothing more annoying (no matter how computer literate you are) to feel like a portal or webchat is a blocker to real human contact. In my mind, that’s not really anything to do with vulnerability. It’s just basic customer service!

The question to ask your tech team

The next time your portal is discussed in the context of vulnerable clients, try reframing the question.

Instead of “Is this appropriate for vulnerable clients?”, I would suggest asking “What would this portal need to look like to actively serve them better than any other channel?”

The answer could be more achievable than you think – and almost certainly more commercially significant than many firms have yet recognised. Clients who feel genuinely supported during their most difficult moments don’t just stay. They refer, they consolidate, and they trust.

If you would like to have a fully confidential, no-obligation chat with me or one of our experts about your digital proposition for vulnerable (and indeed non-vulnerable) clients, please don’t hesitate to reach out. We’re truly passionate about helping wealth management businesses create positive technology experiences for both their colleagues and clients.

You can DM me directly, or get in touch at hello@evotra.co.uk or 020 3410 1966

Written by: 

Sally Merritt, Co-founder and Chief Executive Officer