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As financial reporting regulations for vulnerable people tighten, are you ready?
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As financial reporting regulations for vulnerable people tighten, are you ready?

For our week of thinking on finance and public services, Jonathan Hassell of digital accessibility specialist Hassell Inclusion says that with new regulations, digital accessibility is now a must-have, not a nice-to-have.

Spend just a few minutes online scrolling through social media and you’ll be faced with questions about your life insurance plans or your satisfaction with your bank account.

From email campaigns to online advertising, social media content to influencers, digital channels have become a pillar of financial services marketing strategies.

But financial services companies are also among the most regulated, particularly when it comes to how they market their products.

Worth noting: here in the UK, earlier this year the Financial Conduct Authority (FCA) published new guidance on the use of memes, reels and gaming streams in promoting financial products, including stricter rules for influencers. It warns that promoting products not approved by the FCA could be a criminal offense.

Over the past year, many marketers have also become familiar with the FCA’s new consumer duty, the main aim of which is to “set a higher standard of consumer protection in financial services”. By now, all financial services companies that sell products directly to consumers should have applied the obligation to existing and new products.

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Understanding vulnerable consumers

One of the main aims of Le Devoir is to ensure that “understanding the consumer” is at the heart of all communications, particularly when dealing with vulnerable customers.

Simply put, if consumers are presented with information that they cannot read or understand, or that is presented in a confusing manner, financial services companies could be breaking the rules.

Many people may have characteristics of vulnerability, as defined in the Duty, including poor health, disability, neurodiversity, anxiety, aging or a mental health problem.

A conservative estimate suggests that four in ten people need digital communications to be accessible (due to a range of conditions including visual and hearing impairments, reading or cognitive difficulties, fine motor difficulties which make it more difficult to control of a mouse, or more generally deficiencies linked to aging).

Thus, achieving good digital accessibility is a necessity, not an advantage. And since most customer communications are now done digitally (emails, text messages, online customer service chat functions, PDF statements), all of this needs to be accessible to all customers.

Many businesses already take digital accessibility seriously by following the Web Content Accessibility Guidelines (WCAG) – the technical standards for ensuring accessibility in websites and apps. But if you want to ensure vulnerable people can access your digital tools and services, you’ll need to go beyond WCAG. WCAG does an excellent job of capturing the needs of people with many disabilities, but it leaves out many things that people who are neurodivergent, aging, or with mental health issues need.

Let’s look at two specific and potentially vulnerable audiences: older consumers and neurodivergent people.

The needs of older consumers

A recent report that Hassell Inclusion published reveals that over 65s constitute a very active online communityespecially when it comes to managing finances. 84% of those surveyed said they bank online; almost two-thirds (60%) had taken out an insurance policy.

However, 81% of respondents say they are frustrated by the inaccessibility of websites and apps, while 70% say companies don’t take age-related disabilities into account. Problems encountered include forgetting complicated passwords (37%), confusing site navigation (34%), not having enough time to complete a task before being “timed out” (32 %) and the text is difficult to read (30%). . More than one in ten people (11%) say they have difficulty hearing audio in online videos.

All of these things can lead to increased anxiety levels in the online experience.

Communicating with neurodivergent clients

For neurodivergent clients, the challenges are very different. Each person with a neurodiverse disease is unique. Their accessibility requirements are also unique.

For example, autistic people can focus on their tasks, so if they can’t quickly find the information they’re looking for at the start of a page, they’ll leave. Likewise, too much information can also be overwhelming, as they may have difficulty filtering what is important and what is not. Imagery is also important. When you visit a banking website, you may see an image of a happy family used to advertise a mortgage or credit card, but very rarely the product itself. For autistic people, this kind of imagery simply doesn’t work.

To help businesses understand how to design for these important audiences, we worked with the National Autistic Society to research and develop a set of recommended guidelines.

Accessibility and vulnerability must work together

The key is to bring together your accessibility and vulnerability experts. Vulnerable people may also have a disability and vice versa. So combining vulnerability and accessibility will give financial services marketing teams a more complete picture of all communications, not just websites and online platforms.