Risk & Compliance

Your customers are telling you they are vulnerable. Can you prove you heard them?

Consumer Duty is not a policy problem. It is an evidence problem. Regulators — the Central Bank of Ireland under CPC 2025, the FCA under Consumer Duty — expect firms to demonstrate they identify and respond to vulnerability, not just that they have a policy saying they will.

VibeCheck is an AI-native intelligence layer that reads every customer interaction, detects vulnerability signals against regulatory categories, and creates an audit trail by default. No sampling. No reliance on agents to self-report. Coverage you can defend.

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1.0 The obligation

Three sharpened duties. Each one requires proof, not policy.

The Consumer Protection Code 2025 has been fully in force since 24 March 2026. The consumer definition now covers SMEs, partnerships, clubs and charities up to €5M turnover. Sanctions reach €10M or 10% of turnover. Under SEAR, accountability is individual.

Duty 01

Secure customers' interests

An express duty on top of best interests. The Central Bank expects firms to show — proportionately — the steps they take. Evidence means looking at what actually happens in customer interactions, not what the policy says should happen.

Duty 02

Identify and respond to vulnerability

The definition is now explicit: temporary or permanent. A caller who just lost their partner. Someone who cannot understand the letter they received. A borrower under pressure they did not have six months ago. The regulator expects firms to catch this — not rely on agents to self-report it.

Duty 03

Ensure fair digital delivery

Online journeys, chatbots and self-serve flows are expressly in scope. If a customer struggles through a journey and nobody notices, that is a gap.

In the UK, firms learned Consumer Duty is an evidence problem, not a policy problem. The firms who moved early stayed ahead of it. Ireland is now on the same curve.

2.0 The evidence gap

A two percent QA sample was built for 2012. It will not survive a supervisory conversation in 2027.

Most firms still rely on manual QA teams sampling one to three percent of conversations. Managers coach from memory. Under SEAR, that position is no longer comfortable.

Manual QA Sampling VibeCheck Intelligence Layer
Conversations reviewed 1–3% sampled by a QA team on a schedule 100% of calls, tickets, emails, chats — continuously
When vulnerability is flagged When an agent happens to notice and has time to log it Systemic detection against the six regulatory categories
Consistency across agents Depends on who handled the call and how experienced they are Uniform — same rules, every channel, every agent
If the regulator writes next month A sample of QA scorecards. A slide deck. A project to build the answer Receipts by default — source conversation, timestamp, agent, channel
Cost of coverage Scales linearly with headcount Flat — volume handled by the intelligence layer
Lead time on an emerging issue Discovered in quarterly review, if at all Weeks earlier than warranty or complaints data

The question is not whether your team cares about customers. They do. The question is whether you can prove it across every interaction, consistently, with a trail an auditor can follow.

3.0 Vulnerability signals

Your customers do not say "I am vulnerable." They say things like this.

Six categories, mapped to the Central Bank's guidance on vulnerable circumstances.

01

Financial Distress

"I just don't know how I'll manage this month." Missed payments, mounting arrears, difficulty affording, unexpected income loss.

02

Cognitive Load

"My son is helping me with this." Repeated clarifying questions, misuse of product terms, long silences. A signal, not a footnote.

03

Health & Life Events

Bereavement, illness, caring responsibilities, separation. Temporary vulnerabilities under the Code — and the most commonly missed in isolation.

04

Coercion & Undue Influence

Third-party direction. Reluctance to speak openly. Pattern changes on a call. The new guidance on adults at risk makes this an explicit expectation.

05

Digital Struggle

A failed journey that turns into an angry call. Customers who cannot complete online, who call after a failed step, who are confused about what they agreed to.

06

Accessibility Barriers

If they cannot engage, that is a vulnerability. Non-native speaker friction, hearing difficulty, requests for alternative channels, literacy indicators.

4.0 How it shows up

Insights that come to you. Pushed to where you already work.

Surface 01

Morning Brief

Inbox · 09:01
MON · 21 APR 2026

Your VibeCheck brief, 3 things first

  1. 01
    Financial distress flag · Collections
    CRD-4921, Fri 15:42. Customer arrears mention + "don't know how to manage".
  2. 02
    Cognitive load · Product switch
    Elderly customer, 3 repeat clarifications. Suggest follow-up.
  3. 03
    Digital journey friction rising
    Online application drop-off +14% wk/wk, 6 supporting calls.

A curated view of what changed overnight. Answers one question: what should I do first today?

Surface 02

The Assistant

#conduct-risk · Teams
  • HC
    Head of Conduct 10:14
    Any coercion signals in the last quarter?
  • ✻
    VibeCheck 10:14
    Found 4 flagged interactions in Q1 across Collections and Disputes. All traceable to source.
Flags
4
Agents
3
Outcomes
2 esc.

Ask it anything in any conversation. Grounded in real customer evidence, a compliance expert in every thread.

Surface 03

Evidence Layer

Case receipt
Case
VCI-2847
Category
Financial distress · Critical
Channel
Inbound call · Collections
Timestamp
18 Apr · 15:42:07
Agent
A. Murphy · QT-113
"I've been hospitalised for weeks and I can't manage my account…"

Every insight traces to the conversation behind it. Timestamped, attributed, defensible.

5.0 A day in the life

Monday morning. 9:02am. This is what the control framework looks like, running.

09:02 Inbox
Morning brief arrives. Three vulnerability signals detected Friday — two financial distress, one cognitive load on a call with a customer struggling to understand their options. Each traces to source.
09:20 Follow-up
You review all three. One needs follow-up — flag it to the team lead with the evidence attached. Timestamp, agent, channel, extract. Nothing to dig for.
10:15 In Teams
Your Head of Conduct Risk asks whether there have been any coercion signals in the quarter. You ask the assistant in the thread. Thirty seconds later: four flagged interactions, dates, staff, outcomes.
11:00 Coaching
One team is handling vulnerability conversations significantly better than another. Same processes, same training, different results. You now know where to focus coaching.
14:00 Board prep
You pull a report mapped to the three core CPC 2025 obligations. Population-level coverage, detection rates, digital friction trends. The board sees a control framework operating — not a promise that one will be built.
6.0 Regulatory context

Built for the regulatory environment you are operating in

VibeCheck ships with domain templates for insurance, lending, wealth, payments and financial services. It does not arrive empty. On day one it already knows what matters in your context.

Ireland

CPC 2025

In force since 24 March 2026. Expanded consumer definition. Individual accountability under SEAR. Evidence-based vulnerability identification required.

United Kingdom

FCA Consumer Duty

Established framework. Cross-cutting rules on consumer understanding, support, and price and value. Firms expected to monitor and evidence outcomes at population level.

Applicable across

Every regulated channel

Collections, complaints, servicing, onboarding, digital journeys, telephony — any channel where a vulnerable customer might present.

See VibeCheck on your own data. Twenty minutes.

We will show you VibeCheck running against real customer interactions in a regulated context — vulnerability detection, morning brief, assistant, evidence trail. No slides. Working product.

If there is fit, we scope a pilot within a week. First outputs land in week two.

Twenty minutes. No slides. Working product.
Thanks — we’ll be in touch. We’ll reply within one working day to line up a 20-minute session against your own data.