How AI-powered banking tools are failing vulnerable customers

June 2026
by Payments Intelligence

Introduction

AI-powered tools are reshaping how people bank and pay. Vulnerable customers are among the strongest adopters of digital banking and AI-enabled services, yet new research from The Payments Association’s (TPA) Diversity and Inclusion (D&I) sub-working group suggests they are not benefiting equally from them.

The findings reveal a clear gap between adoption and outcomes. While vulnerable customers engage with digital banking at similar rates to other consumers, they are more than three times as likely to leave a banking or payment task incomplete because a digital or AI-powered tool did not work for them. For firms, this creates both a challenge and an opportunity: those that design AI-powered tools around the needs of vulnerable customers stand to strengthen trust, improve customer outcomes, meet Consumer Duty expectations and serve a wider market more effectively.

Vulnerability is not a niche issue. The research found that 59% of UK adults meet the FCA’s definition of vulnerability, meaning the customers most likely to experience difficulties with digital journeys now represent the majority of the retail banking market.

Key stats

59%

of UK adults are vulnerable on the FCA’s definition, and they adopt AI and digital banking tools faster than other customers.

3x

Vulnerable adults are more than three times as likely to leave a banking or payment task incomplete, at 17% against 5%.

51%

Just 51% of vulnerable customers feel their needs are met well, falling to 32% among those with capability needs.

39%

The most requested improvement is easier access to a human, at 39%, not better AI.

The Financial Conduct Authority (FCA) recognises four drivers of vulnerability: limited capability, including low financial literacy or digital skills; poor financial resilience; health conditions, both physical and mental; and adverse life events such as bereavement, illness or job loss.

Research commissioned by TPA and conducted by Opinium surveyed 2,000 UK adults online in April 2026 and found that 59% meet at least one of these vulnerability drivers. Health is the most common, affecting 38% of adults, followed by financial resilience at 32% and life events at 23%. Capability affects just 3% of adults, but emerges as one of the groups experiencing the greatest challenges with digital financial services.

Importantly, vulnerability is often temporary or situational rather than permanent. Life events such as bereavement, illness, relationship breakdown or a sudden loss of income can affect customers at any stage of life. Vulnerability is therefore not confined to a specific customer segment. It is a condition that many consumers will experience at some point, making it a mainstream consideration for firms designing customer journeys.

TPA member insights

“The results show how important it remains to offer reliable alternative touchpoints alongside digital solutions. AI can simplify many processes, but not every situation can be handled digitally. At Copecto, we see every day the difference that physical cards can make, as they provide a simple and tangible way to access services. It’s important that customers always have the option to choose between different ways of engaging.”

“There is risk with high-speed adoption of new tech that there will be a lack of pause for human-centred issues that merit meaningful consideration. Real thoughtfulness is required relative to the experience of consumers who are vulnerable. This research demonstrates the importance of alternatives for those who find tech difficult and the imperative of human touch points. It is incumbent on all firms to ensure that transformational tech improves the financial lives of all consumers, including those who are vulnerable.”

“This report aligns with Project Nemo's position that AI-enabled build has the potential to make it so much easier to provide a broader range of customer channels that suit a wider variety of needs. However, without being mindful of inclusion in the design or prompts, optimising only for efficiency may inadvertently exclude more people than ever. This risk can be mitigated by involving people with a range of lived experiences and needs in your design and test processes and designing workflows which allow for many permutations of customer journeys.”

“This research should prompt every fintech business payments firm to look hard at how their AI tools are performing for vulnerable customers. At Ecommpay, we know seamless technology only delivers value if it works for everyone — not just the majority. As an industry, we have both a regulatory duty and a commercial imperative to close this gap. Inclusive design isn't a nice-to-have, it’s fundamental to building trust.”

The understanding gap

The understanding gap is not only an inclusion issue. It is also a commercial one. Just 51% of vulnerable adults feel their bank or payment provider understands and meets their individual needs well, compared with 61% of non-vulnerable adults. A similar divide appears among disabled customers, at 50% and 59% respectively. Notably, satisfaction falls between non-vulnerable and vulnerable customers, but changes little as vulnerability becomes more complex, suggesting a common barrier rather than a problem confined to the most severe cases.

The largest gap appears among customers with capability needs. Just 32% of adults with limited financial literacy or digital skills feel their needs are well met, a 28-percentage-point gap compared with non-vulnerable customers. While health, life-event and financial-resilience cohorts all score between 50% and 54%, capability stands out as the clearest area for improvement.

The findings also highlight how failed digital journeys are perceived. Among vulnerable customers who experienced a task failure, 33% felt they received a worse experience than other customers, 20% felt the tool made a negative assumption about them, and 19% felt they had been treated unfairly. Whether intended or not, these perceptions risk eroding trust in digital services.

The cost of failure

Task failure rises sharply as vulnerability becomes more complex. Among non-vulnerable adults, 5% report being unable to complete a banking or payment task because a digital or AI-powered tool did not work for them. That rises to 10% among those with one vulnerability driver, 18% with two, 37% with three and 42% with four. Each additional driver increases the likelihood of failure, suggesting firms should measure outcomes by vulnerability cohort rather than treating vulnerability as a simple yes-or-no category.

The type of vulnerability also matters. Customers experiencing adverse life events report the highest task-failure rate at 26.5%, followed by those with capability needs (24.3%) and poor financial resilience (23.1%). Health-related vulnerabilities are lower at 18%, but still significantly above the population average.

The consequences extend beyond inconvenience. Among vulnerable customers who experienced a task failure, 27% abandoned the task altogether and 14% reported a financial impact, such as a missed payment, compared with just 1.5% of non-vulnerable customers. A further 14% relied on someone else to complete the task, 32% felt stressed, anxious or frustrated, and 18% said the experience reduced their confidence in digital tools. For firms, the cost of poor digital journeys is measured not only in failed transactions, but also in lost trust and customer confidence.

Survey respondent comments

AI blocked an application because of a registered power of attorney.

Male, 77, vulnerable

The AI-powered system did not understand my request and kept sending me in circles with automated responses. I was unable to speak to a human agent, and as a result I couldn’t complete my banking/payment task, which caused delays and frustration.

Female, 34, vulnerable

I was trying to pay a bill online, but the AI-powered chatbot on the bank's website kept misunderstanding me. It wouldn't let me through to a human, and I couldn't get the payment to go through. I felt frustrated, like I was stuck in a loop!

Male, 30, vulnerable

I don't like it it's hard for me to understand them because of some disabilities.

Female, 22, vulnerable

My circumstances weren't in its repertoire so I was in a loop.

Female, 67, vulnerable

The pattern is not uniform. Disabled adults see task failure at 14.6% against 11.4% of non-disabled adults. Age runs counter to the usual assumption: adults aged 18 to 34 report the highest rate at 18%, and it falls steadily with age, to 13% at 35 to 54, 10% at 55 to 64 and 6% at 65 and over. Younger customers use these tools most and so meet their limits most often. High engagement is a strong signal of appetite; the task now is to match it with reliability.

AI and digital tool usage

Vulnerable customers are among the strongest users of AI and digital banking tools, often adopting them at higher rates than non-vulnerable adults. The most widely used are biometric login (68%), chatbots (60%) and voice commands (52%). The largest gaps appear in tools designed to support accessibility and financial management, including spending labels and categories (47% versus 33%), accessibility settings (36% versus 24%) and automated telephone systems (51% versus 41%). Demand for assistive and automated features is clear.

However, usage varies significantly within the vulnerable population. Among vulnerable adults, screen reader use falls from 50% among under-35s to just 4% among those aged 65 and over, while budgeting app use drops from 65% to 10%.

The challenge is that high adoption does not always translate into a positive experience. Among vulnerable users of automated telephone systems, 34% say they make banking harder, compared with 31% of non-vulnerable users. For chatbots, the figures are 28% and 19%, respectively.

The widest gap appears in screen readers, where 15% of vulnerable users say they make banking harder, compared with 6% of non-vulnerable users. As screen readers are intended to improve accessibility, this suggests the issue lies less with the technology itself and more with how it is implemented within banking and payment journeys.

Closing that gap represents a practical opportunity for firms looking to improve outcomes for vulnerable customers.

What customers want from AI

Customers are not asking firms to slow down on AI. They are asking for a human when they need one. The most requested improvement among vulnerable customers is easier access to a real person, cited by 39%, compared with 28% of non-vulnerable adults. Multiple ways to log in or verify identity follow at 22%, staff who better understand people in their situation at 17%, and clearer, simpler language at 15%.

The findings point towards hybrid journeys, where automation and human support complement one another rather than compete. Better protection from fraud and scams is the one priority shared equally by vulnerable and non-vulnerable customers, cited by 25% and 26% respectively. Better tools to manage spending and smarter automated chat also feature prominently.

For firms, the message is clear: the challenge is not whether to deploy AI, but how to deploy it in ways that remain accessible when customers need support. TPA’s D&I sub-working group highlights five practical priorities:

Design inclusively from the outset, applying inclusive-design principles to AI development.
Maintain a human fallback, ensuring customers can escalate to a real person when needed.
Monitor outcomes by vulnerability cohort rather than treating vulnerability as a single category.
Co-create with lived experience by involving vulnerable and disabled consumers in design and testing.
Align AI governance with Consumer Duty and the FCA’s principles-based approach.

These priorities align closely with the FCA’s Guidance on the Fair Treatment of Vulnerable Customers, which encourages firms to equip staff to recognise vulnerability, respond through flexible product and service design, and ensure they are meeting the needs of customers with characteristics of vulnerability.

Designing for what comes next

The regulatory direction is now settled enough to design against with confidence. The FCA has confirmed it will not write a separate AI rulebook, consolidating its position on AI and the FCA: our approach page in September 2025: existing frameworks, the Consumer Duty foremost among them, already expect AI to deliver fair value and avoid foreseeable harm. The standard for firms building tools today is not arriving later. It is live now.

Vulnerability runs through the next phase of that work. The FCA’s Mills Review of AI in retail financial services, launched in January 2026 and reporting to the FCA Board during the year, looks ahead to 2030 and the rise of more autonomous, agentic systems.

Launching it, the FCA’s Sheldon Mills cautioned that consumers may come to rely on AI for decisions they do not fully understand, and that people with thin data histories may face new forms of exclusion. Parliament is pressing the same point: the Treasury Committee’s January 2026 report on AI in financial services urged the FCA to publish practical guidance on applying the Consumer Duty to AI by the end of 2026.

For payments leaders, the opportunity is to lead this shift rather than wait for it. The firms designing inclusive, well-tested AI now are setting the benchmark others will follow, and turning a regulatory expectation into a commercial advantage.