Andrew Gething (pictured), managing director of MorganAsh, said this was compulsory under Consumer Duty.
MorganAsh provides firms with vulnerability tools to help them assess clients.
Gething referred to a recent report by The Personal Financial Research Centre at the University of Bristol which found that three in 10 disabled households were in serious financial difficulty compared to one in 10 non-disabled households.
The study also revealed that just 29 per cent of disabled households were satisfied with the quality of advice or information available to them.
It noted that people with learning difficulties, mental and physical health conditions, mobility issues, chronic fatigue and memory-related issues tended to be worse off financially.
Gething said firms needed to identify, record and report on these challenges.
He added: “The government has received reports like this for a long time – and is looking for the Financial Conduct Authority (FCA) to prevent disabled people from getting worse outcomes. The industry has said for years that this does not apply to them– but, in practice, has no data to back up this view.
“The FCA therefore now requires all financial services firms to provide evidence that the outcomes of their disabled consumers are – at the least – no worse than those of the resilient. In truth, many people have not picked this up that this is a requirement of Consumer Duty.”
The Consumer Duty guidance says the rules support “existing legal requirements, such as those in the Equalities Act 2010, by requiring firms to monitor whether any group of retail customers is experiencing different outcomes than other customers and take appropriate action where they do”.
Gething said this meant firms should report annually on how consumer outcomes differed for those with vulnerabilities and protected characteristics.
He added: “Under Consumer Duty, every firm must understand the consumers’ characteristics and to report on their outcomes at least annually. This is not easy. While the FCA does not explicitly require firms to assess everyone to achieve this, consumer questionnaires will be by far the most cost-effective method, as undertaking ‘some’ post-assessments will be costly and, inevitably, leave considerable gaps in the data.
“Firms should then be able to demonstrate that their disabled consumers fared as well as the resilient. Only then will firms have the evidence to say, ‘this does not apply to us’.”
