Financial vulnerability in the UK is rising.

More than six in ten adults now show at least one characteristic that could make them vulnerable if their financial provider fails to act appropriately. At the same time, 44% (around 20 million people) are living in financially vulnerable circumstances, a sharp rise in just two years.

For many households, financial stability now changes from one month to the next. Incomes fluctuate, costs keep rising, and even a small shock, an unexpected bill or reduced hours, can quickly create strain.

The biggest challenge for firms? Traditional tools cannot provide an accurate picture of a customer’s current situation to allow proactive support. They capture only a moment in time and often rely on data up to 60 days old.

And the FCA’s Consumer Duty is closing in on this issue. Regulators expect earlier risk detection and stronger evidence that customers receive support before their positions deteriorate. And with Open Finance and Smart Data moving from pilots to live frameworks by 2026, continuous oversight will soon be central to how data is shared and decisions are made.

In this blog, we look at how firms are preparing, developing year-round vulnerability strategies that connect governance, data, and customer support ahead of 2026.

Why static checks don’t support a data-led vulnerability strategy

Most vulnerability frameworks were designed for a time when financial difficulty could be identified through forms, phone calls and periodic reviews. But in 2026, those signals are far too slow. The reality is that vulnerability can change within days, yet many monitoring processes still rely on information that is weeks old.

Affordability assessments, income and expenditure forms and quarterly management reports remain central to many customer-care models, but they are retrospective by design. They depend on self-declared data or credit files that are often 30 to 60 days out of date. This delay between reported and actual financial behaviour is where risk often goes undetected and harm occurs.

A customer might still “pass” an affordability check while showing clear behavioural signs of emerging stress:

• Increasing reliance on high-cost or short-term credit.
  
• Gradual erosion of discretionary spending.
  
• Irregular income deposits or missed rent and utility payments.
  
• Rapid growth in gambling or cash-withdrawal transactions.
  

These signals usually surface well before a payment is missed or a complaint is raised. However, traditional systems tend to register them only once the customer has fallen behind.

For risk and compliance leaders, the consequence is clear. Under the Consumer Duty, firms are expected to demonstrate that they can identify and support vulnerable customers before harm occurs. Metrics based on arrears, complaints or broken arrangements can only show what has already happened.

The FCA’s 2024 outcomes review underlined this expectation, calling for firms to use all reasonable data available to identify vulnerability at the earliest stage. Meeting that standard requires information that reflects current financial reality.

And this is where Open Banking data comes in.

Real-time insight through Open Banking: The data foundation for vulnerability strategy in 2026

If vulnerability develops at the same pace as people’s transactions, the data used to manage it needs to move just as quickly.

And that’s exactly what Open Banking enables. It offers a live, consent-based view of how individuals manage income, expenditure, and financial commitments across their accounts, with a level of visibility that static credit files or self-declared information can’t deliver.

From static data to real-time financial signals

Traditional data sources still play an important role, but they show only fragments of the full picture. Open Banking brings those fragments together, creating a continuous connection between affordability and vulnerability.

Rather than replacing existing credit or bureau data, it complements them by showing how customer behaviour is changing in real time.

Examples include:

• Income stability: highlighting volatility or delayed deposits that may point to insecure employment or benefit dependency.
  
• Priority-bill performance: tracking rent, utilities or council tax payments as a measure of household resilience.
  
• Short-term credit use: identifying overdraft cycling, payday loans or recurring BNPL spending before they escalate.
  
• Changing spend patterns: spotting a gradual shift from discretionary to essential purchases (often an early sign of financial strain).

These signals allow firms to move from observation to action. Once firms can see these patterns as they develop, the next step is integration…

Translating data into operational decisions

Open Banking insights become far more powerful when they feed directly into existing affordability models, collections strategies and customer-support workflows. For operations and risk leaders, these aren’t simply red flags; they are decision variables that enable intervention before a missed payment or complaint.

This makes vulnerability monitoring part of day-to-day decisioning rather than a separate compliance activity. And embedding Open Banking insight across the credit journey compounds its impact.

Value across the customer lifecycle

Each stage benefits from real-time data, but together they create a single, consistent view of financial wellbeing.

Stage	Traditional limitation	Open Banking advantage
Application	Self-declared income, limited expense view	Verified, categorised income and spend across accounts (real disposable income)
Monitoring	No visibility until arrears	Continuous insight into financial stability and early stress indicators
Collections	Reactive segmentation by balance	Behaviour-led segmentation, enabling tailored engagement and realistic repayment options
Remediation	One-off I&E forms, little follow-up	Dynamic affordability reviews and auditable evidence of fair treatment

Keen to read more? Instantly access our ebook: How Open Banking is Redefining the Credit Journey from Start to Finish

Organisations adopting this approach are already seeing results. Lenders report faster approvals and fewer affordability complaints. Citizens Advice branches, using Open Banking data in partnership with AperiData and PayPoint, have reduced financial-information gathering for debt advice from three weeks to three minutes, allowing advisers to focus on solutions rather than paperwork. Read the full case study here.

Data built for oversight

The same insight that improves operational performance also strengthens compliance. Because AperiData operates as a regulated Credit Reference Agency, this real-time data meets the governance standards expected of traditional credit data. Each transaction is categorised, explainable and auditable, allowing firms to demonstrate that they are using all reasonable data available to identify and support vulnerable customers.

Open Banking enables an operating model where fairness, compliance and performance are aligned. For firms preparing for 2026, it represents the practical data foundation of a continuous vulnerability strategy… One that connects customer outcomes to regulatory assurance in real-time.

Preparing vulnerability strategy for 2026: building the foundation

By 2026, continuous, data-driven oversight of customer outcomes will be expected across financial services.

Two major developments are shaping this: the Smart Data Bill, which expands secure data sharing across sectors, and the FCA’s Open Finance roadmap, which extends it across financial products. These initiatives are setting the stage for more connected, consistent approaches to vulnerability management.

Smart Data: connecting essential services

The Smart Data Bill, passed in 2025, extends the principles of Open Banking across the wider economy, including energy, telecoms and utilities. Its aim is to create a secure, standardised framework for sharing customer data with consent.

What does this mean in practice? It will allow organisations to verify affordability and hardship indicators using live information from multiple areas such as energy use, broadband bills, rent payments and savings activity, all under a single set of technical standards.

It’s a step change in how vulnerability is defined and identified. It will no longer rely only on financial information but on a broader understanding of household resilience.

Those already working with Open Banking data will be better prepared to adopt Smart Data, having already addressed challenges around consent, security and interpretation.

Keen to read more? Read: Smart Data Bill: The next big thing after Open Banking data

Open Finance: the next layer of visibility

Within financial services, Open Finance builds on the same foundation. It extends data access to savings, pensions, insurance, mortgages and investments, allowing firms to view income, assets, liabilities and liquidity in one consistent framework.

The FCA’s partnership with Raidiam on the Smart Data Accelerator shows that technical and governance models are already being tested.

When implemented, these systems will help firms understand changes in a customer’s financial position in near real time and respond with appropriate support.

Keen to read more? Read: Open Finance will only succeed with reliable data foundations

What this might look like in 2026

In 2026, the most effective vulnerability strategies will use Open Banking today to prepare for the wider Smart Data and Open Finance environment ahead. The same design principles apply:

• Consent-led design: customers stay in control of what data they share and how it is used.
  
• Standardisation: affordability and vulnerability insights can be compared and applied consistently across products and providers.
  
• Operational readiness: data flows feed directly into decisioning and customer-support systems rather than sitting in separate reports.

Embedding these practices early will strengthen Consumer Duty compliance and ensure readiness for a fully interoperable data environment.

Open Banking has already shown that live financial data can improve affordability and vulnerability decisions. By 2026, Smart Data and Open Finance will extend that capability across every customer relationship, giving firms the evidence they need to demonstrate fair treatment as standard.

Firms that understand this are already using 2025 as a testing ground for 2026 readiness: refining consent journeys, aligning governance, and leveraging real-time insights to drive measurable improvements in vulnerability support.

Continuous vulnerability is already within reach

For years, vulnerability management has been treated as a periodic reporting exercise. But by 2026, that approach will no longer be viable.

The data, regulation and technology now exist to identify and support vulnerability as it happens, enabling firms to intervene earlier and evidence outcomes with precision.

And those firms that build continuous, data-led processes in 2025 will enter 2026 with a major advantage.

They will:

• Detect financial stress before it turns into distress.
  
• Evidence fair treatment with verified, explainable data.
  
• Operate within the consent-based frameworks that Smart Data and Open Finance will soon formalise.

Year-round vulnerability management is no longer a compliance goal; it’s an operational capability that defines resilience. The firms that succeed will be those that make vulnerability oversight part of everyday decisioning: measurable, auditable and built into how customers are supported.

Where AperiData fits

AperiData is helping organisations make that transition today.

As a regulated Credit Reference Agency powered by Open Banking, we provide the detailed income, expenditure and vulnerability insight needed to understand customers in real-time.

Our platform turns raw transaction data into categorised, decision-ready intelligence that integrates directly with existing credit, collections and support systems. This allows firms to:

• Continuously assess affordability and vulnerability using live, consented data.
• Base decisions on categorised, explainable information that meets regulatory standards.
• Align governance and reporting with Consumer Duty requirements.

In short, we help firms move from retrospective compliance to continuous confidence, using the same Open Banking data foundations that will underpin the Smart Data and Open Finance era ahead. Learn more about how AperiData supports continuous vulnerability management.