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Signposting for vulnerable customers - going beyond TEXAS


Publication date:

03 April 2020

Last updated:

18 December 2023


Johnny Timpson OBE, FRSA, Financial Inclusion Commissioner, Financial Inclusion Commission

We are now a few short months on from SM&CR being rolled out to intermediary firms and enforcing greater accountability on Senior Managers and certified persons.

It’s also five years since our regulator first published Occasional Paper No. 8: Consumer Vulnerability to stimulate debate on vulnerability so that all in our industry better understood the issue and took steps to act appropriately.

Paper No.8 introduced us to three protocols developed by the Royal College of Psychiatrists and Money Advice Trust to assist colleagues in dealing with conversations around vulnerability. One of these is TEXAS – a protocol which would assist colleagues in managing disclosures effectively, including where to signpost customers to internal or external help when appropriate.


The increased need for signposting

Signposting to specialists is a long established practice in the medical, legal and other professions. It has an increasing role to play in the insurance market given our ageing society, increasing levels of disability, low levels of consumer financial capability and the reduced numbers of financial advisers post Retail Distribution Review (RDR) and Mortgage Market Review (MMR).


A commitment to signposting

In October 2018, as the Department for Work and Pensions’ (DWP) disability champion for insurance (now known as the Cabinet Office Disability Champion for insurance), I hosted a summit at the DWP on improving access to individual, business and group protection insurance. Filling the room was a significant number of leading charities and industry stakeholders who all had one thing in common – a desire to expand access to protection insurance for people with pre-existing medical conditions and/or disabilities.

The meeting resulted in an agreement known as the ‘Caxton House Statement’ which committed to improving access to protection insurance for those very people and saw the formation of the Access To Insurance Working Group. Its four workstreams - underwriting, workplace, signposting and professionalism – were supported by our Charity and Consumer Body Reference Group.


Industry support

Since the British Insurance Brokers Association (BIBA) has extensive experience of running a signposting agreement on age and insurance and of working with Government, I asked them to lead and chair our cross-sector Working Group and deliver the following outcomes: 

  • Develop a signposting system for consumers with pre-existing medical conditions or disabilities seeking protection insurance
  • Support consumer groups and charities by providing guidance and advice about protection insurance
  • Obtain commitment from the wider insurance sector to encourage greater signposting support and promotion.

Following a year of discussion and collaboration across the insurance sector, the Working Group was delighted to launch a new signposting agreement for protection insurance on 21 January 2020.

The 34 (and rising) signatories to the “Agreement on access to protection insurance for people with pre-existing medical conditions and disabilities” comprises both regulated providers of insurance and supporting bodies. The latter will encourage support of the ethos of the agreement and promote its benefits; while providers will signpost customers that they cannot help because of their medical condition or disability towards a firm that can help.

Alan Knowles, Managing Director of Cura Financial Services and the Chair of the Protection Distributors Group, echoed BIBA’s passion about the value of specialist brokers by saying:

“Specialist firms have the experience and expertise as well as the appetite to find solutions for these people who, because of a medical condition or disability, can find obtaining suitable protection insurance a challenge. The launch of this agreement is great for customers and the insurance industry alike.”


How you can get involved

As Cabinet Office Disability Champion for our industry and profession, I ask all colleagues to think about participating in the agreement on access to protection insurance. This is voluntary and will significantly assist those seeking cover.

I’m proud that Scottish Widows is committed to improving consumer access to insurance and signposting to specialists where it is in the customers’ best interests. For more information on signposting and how to access protection insurance visit the Find Insurance pages at


For further reading on signposting and to add to your CPD, read FT Adviser’s recent article.


To hear more from Johnny, read his previous blogs on the Scottish Widows Protect centre.

This document is believed to be accurate but is not intended as a basis of knowledge upon which advice can be given. Neither the author (personal or corporate), the CII group, local institute or Society, or any of the officers or employees of those organisations accept any responsibility for any loss occasioned to any person acting or refraining from action as a result of the data or opinions included in this material. Opinions expressed are those of the author or authors and not necessarily those of the CII group, local institutes, or Societies.