What are vulnerable customers?
Vulnerable customers are people whose circumstances make them more likely to be harmed or disadvantaged when they deal with an organisation. That can be because they find it harder to understand information, to communicate, to pay, to cope with a service failure, or to speak up for themselves.
Vulnerability can come from many places:
- Health: physical or mental illness, disability, or dependence on medical equipment
- Life events: bereavement, relationship breakdown, job loss, a new baby, a house move
- Financial: low or unstable income, debt, payment difficulty
- Capability: low literacy or digital skills, limited English, cognitive impairment
- Safety: family violence or coercive control
- Circumstance: living alone, rural isolation, or recovering from a natural disaster
Vulnerability is often temporary and situational. A customer who is perfectly capable most of the time may be vulnerable during a long power outage in winter.
Vulnerable customers in energy and utilities
Energy is an essential service, so vulnerability carries particular weight. Loss of supply can affect health, heating, cooking and communication, and payment difficulty can lead to disconnection.
In New Zealand, the Electricity Authority’s Consumer Care Obligations have been mandatory since 1 January 2025. They set expectations for how retailers and distributors support vulnerable consumers and medically dependent consumers.
In Australia, the National Energy Retail Rules include hardship requirements for retailers and life support obligations for retailers and distributors. Victoria has its own equivalent framework.
Other sectors, including banking, telecommunications and government services, have their own expectations for vulnerable customers. This page is a general explanation, not legal advice.
How the contact centre makes a difference
The contact centre is usually where vulnerability is first noticed. The way an agent responds can determine whether a customer gets the help available or hangs up without it.
Recognising vulnerability
Customers rarely use the word “vulnerable”. Agents need training to notice cues, such as a mention of illness, confusion, distress or “I don’t know how I’ll pay”, and permission to slow down and ask.
Responding well
- Acknowledge and listen without rushing the customer.
- Ask what would help rather than assuming.
- Explain options clearly, such as payment plans, hardship support, priority handling or registration as medically dependent.
- Record what’s needed, with consent, so the customer doesn’t have to explain again next time.
- Hand off warmly with a warm transfer to a specialist team where needed.
Designing for vulnerability
- Keep a path to a person. Automation suits routine requests, but a well-designed AI-to-human handover should route distressed or vulnerable callers to an agent quickly.
- Prioritise during outages. Build vulnerability questions into fault triage so vulnerable callers don’t wait behind routine enquiries.
- Measure it. Use quality assurance and speech analytics to check whether vulnerability is being spotted and handled consistently.
- Look after agents. Calls with vulnerable customers can be emotionally demanding, so support and debriefing matter.