Customer Treatment Strategies: Protecting UK Consumers from UK Banking Disruptions

The development of Customer Treatment Strategies (CTS) is a strategic response to the FCA’s regulatory expectations outlined in PS21/3 and SYSC 15A, which require firms to proactively minimise harm to customers, particularly vulnerable groups, during operational disruptions. These regulations require businesses to maintain robust internal and external communication strategies that enable rapid, clear, and fair communication for customers, including considering non-technical interventions to reduce harm. 

In the absence of established benchmarks or industry-wide baselines, the development of Customer Treatment Strategies (CTS) presents a unique challenge for those striving to meet the FCA’s expectations which offers limited prescriptive guidance on how to achieve this. As a result, firms must build CTS frameworks from the ground up even when conventional channels of IBS provisioning are unavailable. This includes exploring operational workarounds and practical solutions to ensure that interim customer needs are effectively met during disruptive events. 

During an incident, CTS becomes a strategic differentiator by enabling businesses to lead with customer-centric resilience approach, ensuring that responses are not only operationally effective but also aligned with regulatory expectations for fair, timely, and empathetic treatment, particularly for vulnerable customers.

Between 2024 and 2025, Beyond Blue led the development and refinement of the client’s Customer Treatment Strategies, with a strong emphasis on designing customer-centric approaches to minimise harm in the event of an IBS failure. The team established a robust methodology focused on identifying IBS-specific customer segments and collaborated closely with IBS owners to define the ‘emergency needs’ of these customers. This approach was carefully aligned with the FCA’s regulatory expectations around both Operational Resilience and the Fair Treatment of Vulnerable Customers, ensuring that the treatment strategies are firmly anchored in addressing and prioritising customer needs during incidents.

The team conducted a comprehensive and strategic review to assess how customer harm could be effectively mitigated in the event of a major, potentially prolonged outage impacting one or more Important Business Services (IBSs). This work focused on identifying critical vulnerabilities and designing targeted, customer-centric responses to ensure continuity of service and protection of customer needs during high-impact scenarios. As a result of this work, we identified five strategic focus areas for further review and enhancement, each offering opportunities to strengthen customer outcomes and operational resilience:

• Template Design and Enhancement: Beyond Blue facilitated workshops to refine Customer Treatment Strategy (CTS) templates and associated best practices. This included embedding a stronger focus on mitigating harm across all customer groups, with particular emphasis on identifying and addressing additional treatment considerations for vulnerable customers.  Importantly, the treatment strategies were designed to support a risk-based confidence assessment of their sustainability and effectiveness during major incidents, so the client could maintain consistent and reliable customer support under prolonged or high-impact disruption scenarios. 
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• Establishing a Cohesive Response Framework: We engaged with key stakeholders across the broader response and recovery landscape to define and articulate how Customer Treatment Strategies integrate with existing incident management handbooks and business continuity plans. This ensured a seamless alignment within the overall Response Framework, strengthening coordination and enhancing the organisation’s ability to respond effectively during disruption.
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• Data-Led Response and Treatment: A feasibility study was conducted in collaboration with customer data-owning teams to assess existing technological capabilities and identify areas for enhancement. As part of this initiative, engineering solutions were proposed to strengthen the resilience of key systems of record, which had been identified as potential single points of failure. These systems are critical to ensuring the availability and accessibility of customer data—an essential foundation for enabling timely and effective crisis communication during major incidents.
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• Scaling Through Communication Channels: A validation and feasibility assessment was conducted to evaluate the client’s existing communication channels, with a focus on their ability to scale rapidly during major incidents. The review aimed to ensure that these channels can demonstrate both responsiveness and preparedness, supporting timely and effective customer engagement under high-pressure scenarios.
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• Digitisation of Crisis Communications: We are working with the client to develop an engineering solution that enables the delivery of critical crisis communications in the event of digital infrastructure disruption. The objective is to ensure that our client retains essential, skeleton communication capabilities to support customer engagement during prolonged outages or multiple Important Business Services (IBS) failures. This approach strengthens resilience and ensures continuity of customer support under adverse conditions.

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With Beyond Blue’s support, the client achieved significant progress in strengthening their customer treatment strategies through a series of targeted initiatives. By refining the approach on CTSs and embedding risk-based confidence assessments, they are now better equipped to evaluate the sustainability and effectiveness of their treatment approaches during major incidents—ensuring continuity of support for all customer groups, including vulnerable customers. To support implementation and long-term adoption, Beyond Blue developed a comprehensive suite of resources, including CTS templates, role profiles, framework definitions, and knowledge-sharing sessions with key IBS role holders. These materials provided practical guidance and clarity across all stages of the process. Collectively, these efforts have enhanced operational resilience, improved regulatory alignment, and strengthened the client’s ability to protect and support customers during high-impact disruptions.

A data-driven feasibility assessment enabled clients to proactively identify and mitigate single points of failure within critical systems of record and accessibility of customer data - an essential enabler for timely crisis response. By evaluating the scalability and responsiveness of existing communication channels, they gained assurance that they could maintain effective, high-volume customer engagement during periods of intense operational pressure. In parallel, the development of engineering-led solutions to digitise crisis communications ensured the client could preserve essential communication capabilities even in the face of prolonged outages or multiple IBS failures. Together, these initiatives delivered measurable improvements in customer protection, strengthened digital continuity, and reinforced the organisation’s ability to respond with agility and confidence during high-impact disruption scenarios.

We’re very impressed with the enhanced layout of the Customer Treatment Strategies, which has delivered meaningful enhancements and ease of useability over previous iterations. While we recognise that the Group must continue to mature their approach to mitigating customer harm, the consensus is that this represents excellent progress.