A new report from financial inclusion body Fair4All Finance, authored with PwC, has found that UK financial services consistently produce uneven outcomes for the country’s 16.8 million disabled consumers. The study, titled “Beyond Uneven Terrain: improving the disability landscape in financial services”, draws on reviews of 29 providers, 30 stakeholder interviews and a survey of 102 disabled consumers, and identifies structural failures rather than isolated failures of goodwill.
The researchers estimate that disabled people hold approximately £274 billion in annual spending power, and that a more inclusive financial services market could generate at least £6.4 billion in additional annual economic output. The headline number signals this is not purely a social argument: it is a commercial one.
Three structural failures
The report groups its findings around three interlocking problems.
- The first is what researchers call the “missing middle” in supported access. Many disabled consumers who need help managing their finances face a binary choice: act entirely independently, or hand over control through a formal legal instrument such as a lasting power of attorney. The gap between those two options is largely unfilled, which has pushed some individuals toward informal workarounds such as sharing debit cards, PINs or passwords with carers. These workarounds expose consumers to fraud risk and leave providers without visibility of what is happening in an account.
- The second concerns digital access. Of the 29 providers reviewed, 23 maintained dedicated accessibility pages or hubs, but only nine demonstrated highly visible evidence of testing or co-design with disabled people, and only seven addressed disability or accessibility in their public reporting. Two-factor authentication, verification workflows and periodic app redesigns were all identified as sources of disruption for consumers using assistive technologies.
- The third area covers product decisioning and underwriting. The report found that automated models can make inaccurate assumptions about disabled applicants, producing declines or inflated premiums that the individual has no straightforward mechanism to challenge. Benefit income is treated inconsistently across mortgage affordability assessments: some lenders accept disability-related payments towards affordability calculations; others exclude or deduct them without explanation. One interviewee described being classified as “uninsurable” and said the experience made them feel “as if you’re a leper.”
Regulatory and commercial read-across
The findings arrive in a regulatory environment that is pushing financial services firms toward evidenced, not aspirational, inclusion. The FCA‘s Consumer Duty, in force since July 2023, requires firms to demonstrate good outcomes for all retail customers, including those with characteristics of vulnerability. The Duty puts the burden of proof on providers rather than consumers, and disability sits squarely within the vulnerability definitions the regulator uses. Firms that cannot show outcome monitoring across disabled customer segments face increasing supervisory risk.
Fair4All Finance’s chief executive, Kate Pender, made the commercial case plainly: “Designing an inclusive financial system is not just a social obligation, it is an untapped commercial opportunity that could deliver at least an additional £6.4bn annual boost to the UK economy.”
The report recommends expanding the voluntary Disability Finance Code into retail financial services, piloting supported access mechanisms that protect against fraud without removing consumer autonomy, embedding lived experience in product development governance, and reviewing how automated decisioning and benefit income treatment affect disabled applicants for credit and insurance.
Howard Taylor, director at PwC UK, noted the compound pressures: “Disabled people frequently face higher day-to-day costs and lower average incomes, contributing to lower financial resilience, while also encountering barriers when accessing the products, services and support they need.”
The push to extend the Disability Finance Code across retail financial services is the policy lever worth watching. If adopted at industry scale, it would shift accessibility from a discretionary practice to a defined standard, with implications for product design, underwriting governance and digital channel investment across the sector.
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