---
title: "Vulnerable users (UK and Ireland only)"
description: "Learn how to support potential users in vulnerable circumstances."
url: "https://docs.adyen.com/business-accounts/compliance-guidelines/vulnerable-users"
source_url: "https://docs.adyen.com/business-accounts/compliance-guidelines/vulnerable-users.md"
canonical: "https://docs.adyen.com/business-accounts/compliance-guidelines/vulnerable-users"
last_modified: "2026-06-01T15:33:15+02:00"
language: "en"
---

# Vulnerable users (UK and Ireland only)

Learn how to support potential users in vulnerable circumstances.

[View source](/business-accounts/compliance-guidelines/vulnerable-users.md)

This document assists Adyen partners in identifying and assisting the platform’s users who may be in vulnerable circumstances.

Adyen recognizes that, due to personal circumstances, certain users may have or acquire traits of vulnerability throughout their lifetime. As a result, such users may require additional assistance to fully engage with the offered financial services and to ensure their needs are being met.

In some countries where Adyen offers its financial services, Adyen is obliged by regulation to identify and assist vulnerable customers. To ensure these regulatory requirements are fulfilled, Adyen requires Platforms to adhere to certain processes concerning vulnerable customers, which are outlined in Adyen’s compliance guidelines.

This instruction document is an important component of Adyen’s compliance guidelines. It provides practical, step-by-step guidance on how Platform staff should identify vulnerable customers and the procedures they should follow to ensure vulnerable customers receive the necessary assistance.

Platforms are required to provide the following instructions to all members of staff who interact directly with users.

This includes:

* Customer Support Staff
* Sales and Marketing Staff who communicate directly with users for sales/marketing purposes.
* Managers responsible for overseeing staff who interact directly with users.

Platforms must ensure all in-scope staff members read and fully understand these instructions. Staff should be encouraged to raise any queries. If there is any unclarity, Platforms should **seek clarification from Adyen**.

Agents should be encouraged to properly support the customer and be given all the additional time needed. Your organisation should also flag any support available for agents when they have been dealing with users who are in distress, as these situations can be stressful.

## Identifying vulnerable users

Adyen applies the following definition for vulnerable users:

*“Users who, due to their personal circumstances, are especially susceptible to harm, particularly when a firm is not acting with appropriate levels of care.”*

While all users are at risk of becoming vulnerable, the risk is increased by characteristics related to **four key drivers**:

| Driver      | Description                                                                                                                       |
| ----------- | --------------------------------------------------------------------------------------------------------------------------------- |
| Health      | Physical or mental health conditions that impact a customer's ability to manage their affairs.                                    |
| Life Events | Significant life changes such as bereavement, job loss, or relationship breakdown that can affect resilience and decision-making. |
| Resilience  | Low ability to withstand financial or emotional shocks (for example., tight margins, limited financial reserves).                 |
| Capability  | Low levels of financial literacy, confidence in managing money, or other relevant skills such as digital literacy.                |

### Vulnerability in a B2B Context

Vulnerability is less likely in the B2B context than in retail financial services, but it can manifest for certain segments of Adyen's indirect customer base, particularly sole proprietors.

Indicative examples of merchants who may be prone to vulnerability include:

* Sole proprietors operating with tight margins and limited financial reserves who are susceptible to economic shocks.
* Small e-commerce businesses experiencing a sudden increase in fraudulent transactions and lacking the resources to manage chargebacks.
* Sole proprietors whose health conditions impact their ability to manage business finances effectively.
* A business with an owner who has suddenly become incapacitated, leaving no one with the knowledge to manage online payments.
* A business struggling with cash flow, making it difficult to pay suppliers.
* Elderly sole traders or those with lower digital literacy who may struggle to navigate digital financial tools and processes.

Vulnerability can be temporary. Merchants that do not exhibit signs of vulnerability one day may in fact experience it in the future, and vice versa. It is therefore important to routinely be on the lookout for signs of vulnerability.

## Instructions for staff

### Step 1: Initial Interaction

Greeting and Introduction: Begin every customer interaction with a warm and empathetic greeting. Introduce yourself and let the customer know you are here to help.

### Step 2: Identifying Vulnerability

Indicators of Vulnerability: Pay close attention to the customer's tone, language, and emotional cues. Be alert for any of the following:

* Individual Factors:

  * Passing mentions of illness, disability, or impairment.
  * Reference to contact with the health or social care sector, or receipt of specific benefits.
  * Use of English as an additional language.

* Behavioural Cues:

  * Sounding flustered, anxious, or under duress.
  * Displaying frustration or anger.
  * Asking unrelated questions, forgetfulness, or struggling to concentrate/understand detail.
  * Difficulty regulating emotional responses (being upset, tearful) or difficulty trusting the service/individual.
  * Confusion (for example., not knowing where a debt has come from).

* Wider Circumstances:

  * Mention of life events (time in hospital, bereavement, income shocks).
  * Struggling with the cost of living (mentions of higher bills, struggling to pay household bills).
  * Signs of an unstable housing situation or abuse, including economic abuse.
  * Unexplained spending (which could indicate problem gambling or undeclared debt).

* Organizational Actions:

  * Complaints about things your or another organization may have done (for example, changing communication methods).
  * Mention of failures to deal with a third party/carer, accept a different payment method, or explain key information clearly.

* Example Statements: Statements that could indicate vulnerable circumstances include:

  * “My circumstances are bad, can you help?”
  * “I’m not very well at the moment and am finding it difficult.”
  * “I’m really struggling today, I’m so down.”
  * “I don’t understand you.”

For identifying customers with potential mental capacity limitations, the **BRUCE** method can help identify difficulties with decision-making or limited ability to understand, remember, or "weigh up" information.

| Acronym | Focus Area         | Question to Consider                                               |
| ------- | ------------------ | ------------------------------------------------------------------ |
| B       | Behaviour and talk | Is there a limitation in the customer’s behaviour and speech?      |
| R       | Remembering        | Is the customer experiencing problems with their memory or recall? |
| U       | Understanding      | Does the customer understand the information they are being given? |
| C       | Confusion          | Is the customer confused about the situation or options?           |
| E       | Evaluating         | Can the customer “weigh up” the different options open to them?    |

### Step 3: Providing Support

Use the **TEXAS** method to respond to a customer who has provided information indicating they need additional support.

| Acronym | Action            | Example Script                                                                                                                 |
| ------- | ----------------- | ------------------------------------------------------------------------------------------------------------------------------ |
| T       | Thank             | “Thanks for telling me about your situation, as it will help us take this into account.”                                       |
| E       | Explain           | “Let me explain how we’d like to use that information, just so you know.”                                                      |
| X       | Explicit Consent  | “Are you happy to give me permission to note down and save the information you’ve shared with me today?”                       |
| A       | Ask               | “How does your situation make it difficult to manage your finances?” "How does it affect your ability to communicate with us?" |
| S       | Signpost or Refer | Internally refer to a specialist team, or signpost to external help.                                                           |

Use the **IDEA** method when more information is needed about a customer’s situation to take effective action.

| Acronym | Action     | Example Script                                                                                                                                                                                                                                                            |
| ------- | ---------- | ------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------- |
| I       | Impact     | Ask about the impact of the circumstances on the customer’s financial situation (what does it stop them doing or make more difficult?). For example, “What has the impact been on your personal and financial situation?”                                                 |
| D       | Duration   | Ask about the duration of the circumstances to help determine the time needed to consider options. For example, “So when did this first start to happen?”                                                                                                                 |
| E       | Experience | Understand the customer’s experience of the vulnerability (one-off or recurring?). Take fluctuating situations (including medication effects) into account. For example, “To help me understand your situation better, can you tell me whether this has happened before?” |
| A       | Assistance | Establish what, if any, assistance the customer has received. This helps determine if you need to refer them for additional support from an external agency.                                                                                                              |

If necessary, politely ask the customer for clarification about a condition or illness they mention. For example, “I’m really sorry, but I don’t know very much about (name of condition), could you tell me a little more about it?”

#### Tailor your support

* Customize your approach to meet the customer's specific needs.
* Provide clear and concise explanations and solutions. Use plain language and avoid jargon. For complex topics, break them down into sub-topics and pause for questions.
* Ask the customer if the current channel (chat, phone, etc.) is their preferred communications channel.
* Ask the customer for feedback at appropriate times (for example., when proposing a resolution or next step) to ensure alignment and understanding.

#### Offer Additional Assistance/Signposting

* If the customer needs extra help, offer additional resources or escalate the issue to a supervisor if necessary.

* Ensure that the customer feels supported throughout the process.

* External Signposting Categories (Non-exhaustive list; identify an appropriate organisation in the relevant country/territory):

  * Debt advice services
  * Mental health support services
  * Bereavement counselling services
  * Domestic abuse helpline
  * Disability support services
  * Financial literacy/capability groups
  * Legal aid services
  * Housing advice services.

### Step 4: Documenting the Interaction

A general principle is that customers should only be required to share information about their vulnerability once. The details must be recorded so other staff members who interact with the customer can also meet their needs. The specific vulnerability indicator(s) identified or shared should be recorded using the tags below. A record must be attached to the customer’s file.

Take detailed notes about the customer’s situation, the support provided, and any follow-up actions. Make sure that you only record the facts shared with you by the user and do not include any proposed diagnoses or names of any specific conditions unless the customer has explicitly told you that they have that condition. Please also ensure that the notes are recorded in such a way that you would be comfortable with the customer or a third party reading that about themselves.

| Tag            | Examples of conditions or experiences                                                                                                                                |
| -------------- | -------------------------------------------------------------------------------------------------------------------------------------------------------------------- |
| Health/Ability | Physical or mental health conditions that impact a customer's ability to manage their affairs. These may include: significant illness, health issues, or disability. |
| Life events    | Significant life changes such as: bereavement, job loss, or relationship breakdown.                                                                                  |
| Resilience     | Low ability to withstand financial or emotional shocks such as being in debt or living paycheck to paycheck.                                                         |
| Capability     | Low levels of financial literacy, confidence in managing money, or other relevant skills, such as digital literacy.                                                  |

The following are examples of best practices for user interactions with staff.

| Example                                                                                                                                                       | Vulnerable circumstances tag | Follow-up/support                                                                                                                                                                                                                                                            |
| ------------------------------------------------------------------------------------------------------------------------------------------------------------- | ---------------------------- | ---------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------- |
| Customer explained that they struggled to understand complex financial information and needed additional support in working through the terms and conditions. | Capability                   | Agent offered to spend time explaining terms and conditions (or any other aspect unclear to customer) in further detail. Agent added a note to the customer’s file that additional care may be needed to ensure the customer understands all relevant financial information. |
| Customer appeared to have difficulty in understanding/retaining relevant financial information.                                                               | Capability                   | Agent offered to spend time explaining terms and conditions (or any other aspect unclear to customer) in further detail. Agent added a note to the customer’s file that additional care may be needed to ensure the customer understands all relevant financial information. |
| Customer shared that they suffer from hearing loss and requested that we only communicate with them via email and do not call them.                           | Health/Ability               | Agent added a note to the customer’s file that all communications are to occur in writing and not via call.                                                                                                                                                                  |
| Customer stated that they had recently suffered from a broken down boiler and they needed extra time to pay their fees.                                       | Life events / Resilience     | Agent offered to speak with the finance team and check if additional time to pay can be given.                                                                                                                                                                               |
| Customer shared that their finances are tight following a relationship ending and they needed extra time to pay.                                              | Life events / Resilience     | Agent offered to speak with the finance team and check if additional time to pay can be given.                                                                                                                                                                               |

The following are examples of unacceptable documentation for user interactions.

* Customer did not speak very good English.
* Customer had problems concentrating so may have ADHD.
* Customer had difficulties understanding/remembering so may have dementia.

Consult with your internal privacy or legal teams to ensure that your method of recording is compliant with your company's obligations under domestic privacy legislation such as GDPR.

### Step 5: Follow-Up

If necessary, schedule a follow-up call or email to ensure the customer's issue has been resolved. Confirm that the customer is satisfied with the resolution. We recommend that you periodically review your interactions and feedback to continuously improve the handling of vulnerable users.

## See also

* [Reporting on vulnerable customer information](/business-accounts/compliance-guidelines/reporting-to-adyen#periodic-reporting)
