• The FCA's Financial Lives 2024 survey found 26.4 million UK adults (49%) showed at least one of four vulnerability characteristics as of May 2024, down from 27.3 million (52%) in May 2022.
• Finextra's analysis frames the industry's real-time-payments and app-first rollout as a design failure that assumes a smartphone-literate, PIN-capable customer.
• The most concrete industry response is Money Carer's biometric 'carer card,' built with Tag Systems and Fingerprint Cards AB and launched in May 2024, which replaces PIN entry with a fingerprint tap.
• Money Carer has since extended fingerprint authentication to wearable rings and bands under a product line called Touch.
• The fix is opt-in and vendor-specific rather than a default embedded in mainstream current accounts or FCA Consumer Duty requirements.

Nearly half of UK adults — 26.4 million people, per the FCA's Financial Lives 2024 survey — now carry at least one recognized characteristic of financial vulnerability, and the banking industry's rollout of real-time, app-first payments is outpacing the design work needed to serve them. The sector's only concrete response so far, a biometric card from appointeeship specialist Money Carer, is a niche retrofit built by third-party vendors, not a default embedded in mainstream current-account design or FCA Consumer Duty compliance.

The scale the industry is designing around

Nearly half of UK adults now carry at least one recognized characteristic of financial vulnerability, according to the Financial Conduct Authority's Financial Lives 2024 survey, published in May 2025 from fieldwork conducted in May 2024. The regulator counted 26.4 million adults — 49% of the population — with poor health, a negative life event, low resilience or low capacity, a figure down from 27.3 million (52%) in May 2022. That population is the baseline against which any bank's real-time-payments rollout has to be measured, not an edge case.

Speed is being sold as inclusion, but the two aren't the same

Finextra's analysis argues that the industry's enthusiasm for real-time payments and app-first banking has outrun the needs of customers who cannot reliably use a smartphone, remember a PIN, or navigate a banking app unassisted — precisely the population the FCA's vulnerability characteristics describe. The publication frames this as a design failure rather than a technology failure: faster rails and slicker interfaces are being treated as universal upgrades, when for some customers they function as a new access barrier layered on top of existing ones.

The one shipped fix: a fingerprint instead of a PIN

The clearest concrete response so far comes from Money Carer, a UK social enterprise that manages finances for vulnerable adults under formal appointeeship and deputyship arrangements. In May 2024, Money Carer, card manufacturer Tag Systems and Swedish biometrics supplier Fingerprint Cards AB launched a biometric 'carer card' letting a cardholder authorize payment with a fingerprint tap instead of a PIN. Money Carer CEO Sean Tyrer said in the companies' launch announcement that the PIN itself — not the underlying payment rail — is the barrier to financial inclusion for many clients with memory or visual impairments. Money Carer has since extended the same model to wearable rings and bands under a line it calls Touch.

Banks aren't building this — specialists are

The structural point is what the biometric card reveals rather than what it solves: the fix for PIN- and app-dependent exclusion is coming from a niche appointeeship specialist and two hardware vendors, not from a mainstream bank's core current-account design or a Consumer Duty compliance program. No major UK retail bank has published a comparable fingerprint-first payment default for vulnerable customers; the accessibility work is being outsourced to third-party card issuers layered on top of existing rails, one partnership at a time.

What to watch

The FCA's Consumer Duty already requires firms to consider harm to vulnerable customers, but the regulator has not mandated any specific payment-authentication alternative to PINs or app-only banking. Whether the next Financial Lives survey shows the 26.4-million figure falling will depend less on niche products like Money Carer's card and more on whether card networks and core banking platforms build biometric or assisted-access options into standard current accounts, rather than selling them as an add-on for a segment the FCA has already sized at half the adult population.