MorganAsh launches gap analysis service to help firms benchmark against new vulnerability management guidance

MorganAsh, a vulnerability specialist and support services provider, has launched a new gap analysis service to help firms assess how their current approach to customer vulnerability management aligns with new benchmark guidance

Related topics:  Consultancy,  Vulnerable Customers
Editor | Modern Lender
27th January 2026
Andrew Gething

MorganAsh, a vulnerability specialist and support services provider, has launched a new gap analysis service to help firms assess how their current approach to customer vulnerability management aligns with new benchmark guidance.

The new service is available to all financial services firms and aims to provide clarity on how firms compare to the higher standards set out by the Chartered Insurance Institute (CII) and Personal Finance Society (PFS) – which have now been adopted by the Financial Ombudsman Service (FOS) as the de facto standard for vulnerability management.

The gap analysis sets out the key areas identified in the latest guidance, such as identification, customer support, data and systems, lifecycle management, reporting and audit trail. Each section provides a range of questions to evaluate where firms currently stand and determine areas for improvement and investment.

Since its launch late last year, the new vulnerability management guidance has received positive feedback from across financial services, effectively becoming the standard. It is designed to give all firms a practical action plan to embed the principles-based regulation of Consumer Duty, focusing on the necessary IT systems, processes and data infrastructure required by firms to identify, classify, monitor, support and report on customer vulnerabilities and outcomes.

Andrew Gething, managing director of MorganAsh, said: “The CII guide is an excellent and thorough specification of what is required in vulnerability management to meet FCA Consumer Duty regulations. But we know many firms struggle to communicate the challenges of vulnerability across management. This gap analysis simplifies the requirements to 33 yes/no questions so firms can quickly and easily benchmark themselves against the standard and communicate this easily across management.

“With this higher benchmark now recognised and adopted as the standard by FOS, now is the time for firms to look at all areas of their approach to see how they compare. While very few firms are likely to meet all the criteria of the gap analysis, those who find themselves unable to meet multiple parts of this criteria will quickly see a need for improvement and further assistance. It’s an opportunity to really raise standards and processes – helping firms on the journey to leveraging the commercial benefits and competitive advantages of a regulation that encourages firms to know customers better, to tailor products and services, and deliver better outcomes.” 

MorganAsh is a specialist in Consumer Duty and customer vulnerability. The firm launched its multi-award-winning MARS platform to help firms understand and monitor vulnerable customers and deliver good outcomes – as required by Consumer Duty. It is in use across financial services and the utilities sector, enabling businesses to adopt a consistent approach to identifying vulnerable characteristics and generate an objective Resilience Rating – much like a credit score.

The MARS platform meets the system requirements set out in the new guidance, providing financial services firms with a proven tool that can be used as a standalone system or integrated into other systems via an API (application programming interface).

Along systems support, MorganAsh also provides consultancy and a range of workshops to help firms navigate their customer vulnerability journey.

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