Dependency: The blind spot in financial planning
On 13 March 2026, the Financial Conduct Authority published a Consumer Duty review titled Consumer understanding: good practice and areas for improvement. Much of it focuses on how firms communicate with customers and whether customers understand the financial decisions they make.
Reading it raises a broader question for financial planning and Special Needs Planning: how early in the advice process do firms identify dependency within a family?
Where dependency hides in a family
Dependency isn’t always visible in the client sitting across the table. Often it sits somewhere else in the household:
- a disabled adult child who will rely on financial support for the rest of their life
- a vulnerable beneficiary within a trust
- an older relative who needs long-term care
A fact find built around the client alone can miss all three.
How dependency changes financial planning decisions
Where dependency exists, financial planning decisions behave very differently:
- Longer time horizons. Trusts, such as discretionary or disabled person’s trusts, may need to run for decades, not years.
- Liquidity planning. Cash flow may need to cover care costs or supported living, now and after the parents have gone.
- Governance and succession. Who holds decision-making authority, and how it passes across generations, matters far more.
- Benefits protection. Poorly structured gifts or inheritances can affect a dependant’s means-tested benefits.
None of this is new technically. Financial services already has the legal structures, investment expertise and governance to support complex families. What’s much less common is identifying dependency early enough to use them well.
Why dependency surfaces too late
In many advice processes, dependency emerges late: during trust discussions, succession planning or, sometimes, only after a bereavement. By then, the financial structures may already be in place.
Structural vulnerability and the Consumer Duty
The FCA’s review asks firms to think carefully about how they recognise and respond to vulnerability. It found that many firms were reactive rather than proactive, and it highlighted good practice such as identifying needs early and building disclosure prompts into the fact find.
Much of that discussion focuses on communication and disclosure. But vulnerability can also be structural: it can lie in the way family members depend on one another financially.
Where dependency exists, planning decisions can shape outcomes for decades and affect people who were never part of the original conversation. That’s why identifying dependency early matters.
Five questions to identify dependency early
Adding a few questions to the fact find can bring dependency to the surface at the start, not the end:
- Does anyone in the family rely on you financially now, or might they in future?
- Does anyone in the household have a disability, long-term condition or additional needs?
- Does anyone receive means-tested benefits or social care support?
- Who would make financial decisions for that person if you couldn’t?
- Are there existing trusts, wills or powers of attorney that name a vulnerable person?
SENDA helps financial, legal and charity advisers build dependency into their process from the first meeting. Explore our Special Needs Planning training or talk to us about consultancy. To stay up to date, sign up to our monthly newsletter.