A new report calls on financial services to embed accessibility at its core, ensuring people with learning disabilities are not excluded.
by Kerry Berchem, ESG Working Group member and practice development lawyer,
Burges Salmon.
Project Nemo describes itself as a “catalyst for change”. The initiative uses lived experience to bridge the gap between the UK’s fintech industry and people for whom a learning disability creates barriers to financial access. Its recent report, ‘Safe Spending for Adults with a Learning Disability: A Call to Action for Financial Services’, sets out practical steps for embedding accessibility into products and policies so that services meet real people’s needs.
Charlie Bronks, SVP group head of sustainability at Crown Agents Bank and co-lead of The Payments Association’s (TPA) ESG Working Group, said the report is “a powerful reminder that financial inclusion must be built on lived experience”. She argues that the payments industry has a responsibility to design services that are not only accessible but empowering, highlighting the practical measures in the report that could “transform how people with learning disabilities engage with money— restoring independence, dignity, and confidence”. For Bronks, the message is clear: it is “a call to action for all of us to ensure that financial services work for everyone, especially those who have been excluded for far too long”.
Traditional financial services were not designed with the needs of people with a learning disability in mind. Joanne Dewar, co-founder of Project Nemo, cites the idea behind the specific focus of the report was that the community “was one of the most adversely impacted by the move from cash to digital and at the same time, most likely to be targeted by fraudsters, so it is imperative we have solutions that provide adequate support and protection.”
Today, providers must ensure safe, accessible, and trusted solutions for everyday money management across the UK. Dewar champions disability accessibility being a focus for all financial firms: “Armed with the facts, alongside the other three workstream deliverables, all firms are able to take action to ensure more safe spending options are available.” While Project Nemo focuses on a specific group, its recommendations could drive wider improvements for many others who also face barriers to the most basic financial services.
Project Nemo has given a platform to people who have been financially excluded, making their voices heard in a space where they were often invisible. The initiative has identified solutions to prevent exclusion from society through a lack of access to financial services. As the report notes, financial exclusion undermines not only bank balances but also well-being, confidence, and independence.
For Miranda McLean, CMO at Ecommpay, accessibility is “absolutely critical for a positive and sustainable economy”. She explains that this commitment underpins the company’s partnership with Project Nemo: “There must be an ongoing commitment to regular accessibility reviews, updates, and improvements to turn the tide and deliver a truly accessible financial service. The latest report provides clear direction on steps that will enable a more inclusive financial ecosystem.”
Key findings and recommendations Project Nemo makes five key recommendations for the development of financial services capable of meeting the needs of those with learning disabilities:
1) Personalisation is the cornerstone of inclusive financial services accessible by design. Services should be flexible enough to meet different needs—for example, apps with a ‘calm mode’ to reduce anxiety, supporter cards for trusted third parties, safe spending limits, and information available in alternative formats such as easy-read versions.
Quick win: Provide information in an alternative format, for example, an easy-read version.
2) Financial exclusion directly affects well-being and independence. To manage money confidently, people with learning disabilities need tools that support independence rather than over-reliance on carers or third parties—some of whom may not be trustworthy. Practical steps include alerts to customers and/or supporters before transactions are approved, especially for larger or risky purchases.
Quick win: Alerts to the customer and/or supporter before a transaction is approved, especially for larger or risky purchases.
3) A stronger focus on the financial needs of people with a learning disability is essential. Many require extra support to understand balances, make spending decisions, and engage with providers. Firms can help by offering specialist staff, simplifying processes, and reducing anxiety triggers, such as queues in branches—for example, by providing quiet rooms at off-peak times. More tailored support is also needed around life transitions, such as moving from a child to an adult account. Accessibility support should be easy to find across websites and documents.
Quick win: Make it easy to find accessibility support on websites and documents.
4) Risky workarounds expose individuals to harm. Because many mainstream financial services do not meet their needs, people with learning disabilities are often forced to improvise—for example, by sharing passwords or having another person pose as the account holder. Around 32% do not have a bank account in their own name. Safer, tailored solutions are needed to reduce these risks, such as allowing customers, or their supporters to set daily, weekly, or monthly spending caps.
Quick win: Ability to set daily/weekly/ monthly spending caps (chosen by the customer and/or supporter).
5) Specific features could transform financial accessibility. Practical design changes can reduce stress and confusion, making people with learning disabilities feel more confident and in control. Examples include using clear and simple language, visual guides, and colour coding of critical information. Services should avoid jargon, keep text concise, and ensure digital tools have clear menus, logical structures, and effective search functions. These measures are not superficial improvements: they can fundamentally change how accessible and empowering financial services feel for people who might otherwise be excluded.
Quick win: Avoid jargon and keep text concise. Use clear menus, logical structure, and search functions.
Imran Ali, payments consulting director at KPMG and co-lead of TPA’s ESG Working Group, stresses the importance of inclusive design in financial services. “Applying principles of inclusive design is key to helping remove barriers to financial services for individuals from communities that are often excluded from such access,” he says. Ali adds that Project Nemo “puts the lived experiences and voices of people with learning disabilities at the heart of solutions and actions aimed at driving inclusivity within the fintech industry.”
Vulnerable customers include not only those with a learning disability but also other excluded groups like those with learning difficulties (which are distinct from learning disabilities), the elderly, those who are financially inexperienced, those in financial difficulty, the bereaved, those experiencing employment insecurity, and those who are unwell. While these customers may not share the same vulnerabilities, they may share common disadvantages in their financial lives, including reduced levels of financial well-being, lower incomes, higher costs, and fewer opportunities.
Project Nemo has given a platform to people who have been financially excluded, making their voices heard in a space where they were often invisible.
Identifying and managing vulnerable customers is a complicated challenge with which the financial services industry has struggled for some time. However, the Financial Conduct Authority (FCA) expects firms to support customers to access financial services, to improve consumer confidence and financial wellbeing, and to ensure that vulnerable customers get the support they need. Succeeding in this is not only ethical, it’s vital to ensure wider compliance with the Consumer Duty and that everyone can “manage their money with confidence, dignity and independence”.
For accurate insight into the needs of this customer group, Project Nemo commissioned specialist research into the “specific experiences, needs, and wants of people with a learning disability in managing their finances”. This enabled an in-depth understanding of the unique needs and everyday challenges of real vulnerable consumers, the solutions that have been created to allow them to overcome the barriers to access, and to test their responses to potential solutions.
This has enabled knowledge gaps to be filled with meaningful information and the creation of solutions that will really work for those who most need them. This research identified a number of solutions which could facilitate greater financial inclusion, including assistance to get to a branch, assistance to deal with the bank via means such as web chat or call centres, and prompts to remember a PIN (or alternatives such as phone based, or facial or fingerprint recognition, payment methods), log-in or password, or help to understand whether something is an error or scam.
With the increasing digitalisation of financial services, challenges often emerge alongside solutions. Digital solutions have facilitated several improvements to vulnerable customers, such as being able to set up accounts and manage money remotely. However, people with learning difficulties and other characteristics of vulnerability face their own unique difficulties concerning technological change. Many face barriers, including difficulty understanding bank products or terms, sensory overwhelm, or difficulty remembering login information.
The fintech industry has the technological ability and the agility to create and deliver inclusive and accessible financial services solutions needed by vulnerable people, not just those with learning disabilities, but also other previously excluded groups that could benefit from similar changes. These people can be empowered to make better financial choices and enabled to experience improved financial lives. Project Nemo highlights the need for payments firms to:
With comprehensive, industry-wide implementation, the benefits of Project Nemo could be extended well beyond those affected by learning disabilities and into significant numbers of other vulnerable and underrepresented individuals.
Christian Shiba, ESG manager at Pay.UK, describes Project Nemo’s work as vital to making financial services fairer and more inclusive. “Project Nemo’s campaign to support the FinTech industry on financial inclusion through insight and action is essential to ensuring fair and equitable access to products and services that can drive real-world benefits for end users,” he says. The report, he notes, “not only shares the scale and context of those excluded or underserved from the system but also shows how this affects people as individuals. We are excited to see how the ecosystem can adopt the recommendations to make use of existing systems and innovate and expand access to ensure that it reduces harm and supports wellbeing, in line with our own goals.”
If payments firms took up the mantle of effectively implementing all of the suggestions Project Nemo poses in their report, the benefits for people previously excluded from financial services would include seemingly simple, but vital, things such as the ability to go out with their friends, to buy something they want, or to save for something that they dream of.
With comprehensive, industry-wide implementation, the benefits of Project Nemo could be extended well beyond those affected by learning disabilities and into significant numbers of other vulnerable and underrepresented individuals. We all, every one of us, have a vested interest in making sure that real change can be implemented because every one of us may at some point in our lives become vulnerable, even if temporarily, and every one of us will, at that time, rely on financial services working as we need them to.
