Customer journeys and vulnerability lessons from the FCA’s basic bank account review

What happened?

On 7 July 2026, the FCA announced that nine of the UK’s largest banks and building societies had committed to improving how they offer basic bank accounts, following a mystery shopping exercise. Basic bank accounts are designed to give people without access to standard current accounts essential banking services, without fees or overdraft facilities.

Across 298 mystery shopping interactions, around a third were rated poor or very poor. Customers who may have benefited from a basic bank account were not always told the product existed, and some vulnerable customers were directed towards online application journeys unsuited to their circumstances. The FCA identified particular challenges for customers experiencing financial hardship, those without standard forms of identification, and individuals with no fixed address.

Why does it matter?

The review shows that although basic bank accounts exist, the customers they are intended for may not always be able to complete a successful journey to access them. Under the Consumer Duty, this matters because good outcomes depend on whether products, communications, processes and people work together in practice, not simply on whether a suitable product is available.

Just days before the announcement, the FCA also proposed reforms to simplify investment disclosures, noting that only 6% of the investment disclosure documents it reviewed for readability were written in plain English. Both findings reflect the FCA’s growing focus on what customers actually experience, rather than what firms intend them to experience.

Who is affected?

Banks and building societies offering basic bank accounts are directly affected, particularly those serving customers experiencing financial hardship, previous bankruptcy, or difficulties providing standard identification.

The lessons extend more broadly to any firm whose products depend on a customer completing an onboarding or application journey, especially where vulnerability characteristics may affect a customer’s ability to do so.

Key risks

• Customers who could benefit from a basic bank account not being told the product exists.
• Vulnerable customers being directed towards online-only application journeys unsuited to their circumstances.
• Frontline staff not recognising when a customer could benefit from a basic bank account, causing the journey to break down at the first interaction.
• Assuming that a compliant product, governance framework and communications are sufficient without testing the actual customer journey.

Actions to take

1. Test customer journeys directly, using mystery shopping, customer testing or outcome monitoring, rather than assuming intended outcomes are being delivered.
2. Review onboarding routes for customers with no fixed address, limited identification, or financial hardship, and offer alternative routes where needed.
3. Ensure frontline staff understand which products exist, who they are designed for, and when to raise them with customers.
4. Confirm ownership and accountability for monitoring and improving customer access and support outcomes.

Wider implications

The review reinforces that good customer outcomes are rarely determined by products alone; they are shaped by the quality of the journeys surrounding them, the effectiveness of communications, and staff capability to recognise and respond to customer needs.

This lesson extends beyond basic bank accounts and beyond banking: a product can be suitable, communications technically compliant and governance robust, yet customers can still experience poor outcomes if they encounter friction during the journey itself.

Recommendations

Firms should look beyond individual products and consider the entire end-to-end customer journey, testing it from the customer’s perspective rather than relying solely on governance reviews.

Vulnerability frameworks should be assessed not only on whether they identify vulnerable characteristics, but on whether the process remains accessible once those characteristics are present.

At TCC, we help firms deliver effective compliance that connects regulatory expectations, operational reality and customer outcomes.