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Cavefish
FCA Consumer Duty, Regulatory Sandbox

Vulnerable client signals your team can't currently see. EchoDepth makes them visible.

Updated October 2026

FCA Consumer Duty requires documented evidence that vulnerable customers received appropriate treatment. Standard QA reviews only a sample of interactions, so vulnerability signals in the rest often go unseen.

EchoDepth analyses voice, video and text in real time - detecting distress, anxiety and cognitive overload before harm occurs, and generating the audit trail your compliance team needs.

No wearablesVoice-first for phone callsGDPR compliantFCA Sandbox tested
EchoDepth · Live Vulnerability Detection
Key phrase detected
“I don't know how I'll pay…”
0.22
V · negative
0.91
A · extreme
0.18
D · low
▲ VULNERABILITY FLAG
Tier 2: financial distress
Route to trained handler · Pause recovery action · Document for Consumer Duty file
Risk Score8.4 / 10
ConfidenceHigh
AU1+4 brow tensionSustained 18s
Action requiredImmediate
All vulnerability determinations remain with qualified staff. EchoDepth provides evidence, not verdicts.

Hear who needs more care

Many vulnerable customers never say so. How EchoDepth reads the signals in their calls, scores each interaction and keeps the audit record Consumer Duty asks for - with qualified staff making every decision.

Read the transcript

Under Consumer Duty, firms must deliver good outcomes for every customer. Including the ones who never say they're struggling.

Many won't tell you. Bereavement, illness, money worries. Some don't recognise it in themselves, and some don't want to say.

But it often shows in how they speak. The pace slows, the pauses grow, and the words start to change.

EchoDepth listens for those signals in every call. Distress, anxiety and cognitive overload, from vocal patterns, pace, hesitation and language. No declaration needed.

Each interaction gets a Vulnerability Signal Score, with the moments that drove it, timestamped.

So your team can slow down, check understanding, or bring in specialist support, while the customer is still on the line.

And every call leaves an audit record: vulnerability was assessed, and here's what happened next. That's the evidence Consumer Duty asks for.

It matters most where harm is likeliest. Collections, complaints, and difficult decisions like a loan decline.

EchoDepth flags. People decide. Every determination stays with qualified staff, under UK GDPR, with consent built in.

EchoDepth. Hear who needs more care, while there's still time to give it.

Watch on its own page
Active
Consumer Duty enforcement
The FCA publishes enforcement outcomes and annual reports. Check its latest figures directly.
FCA source
Sampled
Standard QA coverage
Standard QA reviews only a sample of interactions. The vulnerability signal can exist in the rest.
Every call
Auditable evidence with EchoDepth
Each analysed interaction generates a timestamped vulnerability assessment record.

Four-tier framework. Automatic routing.

EchoDepth classifies every interaction against a validated vulnerability tier framework - triggering the appropriate response before harm occurs.

TIER 0
Standard
No flag

No elevated emotional markers. Standard interaction protocol.

TIER 1
Elevated
Monitor

Elevated arousal or low valence. Continue with care. Note in case file.

TIER 2
Financial Distress
Intervene

Significant distress markers. Route to trained handler. Pause recovery action.

TIER 3
Crisis Indicators
Escalate

Extreme distress or crisis-level signals. Immediate escalation. Signpost specialist support.

Designed for where the risk is highest.

01
Compliance

Complaint Escalation

ECA escalations are rarely surprises to the customer. The emotional signals - frustration, distress, a sense of being dismissed - build across every interaction. EchoDepth reads those signals in real time, giving your team the chance to intervene before a complaint becomes a regulatory case.

→Sustained elevated arousal - building frustration across a call
→Valence drops when specific decisions are communicated
→Dominance collapse - customer feeling powerless or dismissed
→Temporal escalation pattern - emotional state worsening over time
Consumer Duty - A complaint that escalates after emotional distress signals were present and unaddressed is a documented regulatory failure. EchoDepth closes this gap.
02
Lending

Loan Decision Communications

A loan decline is not just a business decision. For many customers, it arrives at a moment of genuine financial crisis. EchoDepth analyses the communication quality of video affordability interviews, flagging risk signals before a decision is communicated without appropriate care.

→Continuous VAD monitoring throughout the application session
→Distress flag triggered before decline communication is issued
→Vulnerability tier scoring - financial distress and mental health indicators
→Automatic routing to trained handlers on threshold breach
Consumer Duty - The manner in which a decline is communicated can determine whether a customer spirals into harm or receives appropriate support. Consumer Duty requires evidenced appropriate treatment.
03
Collections

Debt Recovery Interactions

Vulnerable customers are disproportionately represented in collections portfolios - and disproportionately harmed by inappropriate treatment. EchoDepth provides collections teams with real-time vulnerability signals, flagging the moment they emerge so interactions can be redirected before harm occurs.

→Voice-first vulnerability detection during phone calls
→Tier classification: financial distress, mental health indicators, situational vulnerability
→Automatic redirect to trained vulnerability handlers on flag
→Session report with vulnerability evidence for regulatory file
Consumer Duty - FCA enforcement against collections failures is increasing. Documented evidence that vulnerability was identified and acted upon is a regulatory requirement, not a best practice.
04
Fraud

Fraud & Claims Investigation

Fraud investigators deal daily with distinguishing genuine distress from performed distress. EchoDepth adds a physiological layer independent of what the subject says - identifying moments where the emotional profile diverges from what a genuine account would produce.

→Baseline establishment from session opening minutes
→Topic-linked anomaly detection - which questions triggered which responses
→AU24 lip press and AU17 chin raiser - suppression markers
→Structured report with timestamped anomalies for the case file
Consumer Duty - This is not lie detection. It is the identification of physiological inconsistency - flagged for qualified human review, not automated determination.

The maths is straightforward.

Fewer escalations reduce remediation cost every year - before accounting for reduced FCA scrutiny, avoided fines and reputational protection.

Annual volume modelledYour own interaction volume
Vulnerability detection improvementMeasured in proof of concept
Escalation rate reductionMeasured in proof of concept
Estimated annual savingsCalculated from your data
Proof of Concept scopeSee pricing
Year one ROICalculated from your data

Illustrative structure only. No modelled figures are presented as results; measure outcomes with your own data in a proof of concept.

FCA fine avoidance

Documented Consumer Duty evidence is your primary defence against enforcement action.

Proactive remediation

Intervening before harm occurs is generally less costly than post-complaint remediation.

Reputational protection

Documented vulnerability assessment process demonstrates regulatory maturity to the FCA, boards and investors.

Consumer Duty evidence

Every session generates a timestamped vulnerability assessment record - the audit trail Consumer Duty requires.

“EchoDepth does not detect lies. It measures the involuntary physiological markers that accompany stress, cognitive load and emotional state change. What organisations do with those signals is a matter of process, policy and human judgement.”

Cavefish ethics framework: this distinction is non-negotiable in every deployment

Common questions

How does EchoDepth support FCA Consumer Duty compliance?

EchoDepth detects emotional distress, anxiety and cognitive overload signals in customer interactions - generating a Vulnerability Signal Score and timestamped audit record for every session. This creates documented proof that vulnerability was assessed for every interaction, directly satisfying Consumer Duty evidencing requirements.

Does the customer need to self-declare vulnerability?

No. EchoDepth detects vulnerability signals from vocal patterns, speech pace, hesitation patterns and linguistic markers - without relying on customers to identify or disclose their own situation. This is particularly important for customers experiencing mental health challenges, bereavement or acute financial distress who may not recognise or wish to declare their vulnerability.

What modalities does EchoDepth analyse for vulnerability detection?

EchoDepth is voice-first for phone-based interactions - where most collections and complaint calls happen. It also analyses video (facial Action Units, expressions), text (transcripts, written communications) and still images. The modality is matched to the interaction type.

What is the typical ROI?

The return depends on your own volume of vulnerable-customer interactions, your current escalation rates and your remediation costs. A proof of concept on your own call data is the way to measure it.

Is EchoDepth GDPR compliant for financial services use?

Yes. Cavefish operates under UK GDPR and ICO frameworks (ICO registration ZB915633). All deployments include explicit informed consent architecture and a signed Data Processing Agreement. EchoDepth has been used within the FCA Regulatory Sandbox.

How does EchoDepth avoid becoming a substitute for human judgement?

EchoDepth generates evidence and flags - it does not make decisions. All vulnerability determinations, interaction redirects and customer outcomes remain with qualified staff. The platform provides the physiological evidence layer that supports human decision-making under Consumer Duty.

How does EchoDepth classify vulnerable customers?

EchoDepth classifies vulnerable customers by scoring every interaction against a four-tier vulnerability framework, and each tier triggers a defined response. Tier 0 is Standard, with no flag and the standard interaction protocol. Tier 1 is Elevated, which means monitor: elevated arousal or low valence is noted in the case file. Tier 2 is Financial Distress, which means intervene: significant distress markers route the interaction to a trained handler and recovery action is paused. Tier 3 is Crisis Indicators, which means escalate: extreme distress or crisis-level signals trigger immediate escalation and signposting to specialist support. Classification draws on vocal patterns, speech pace, hesitation patterns and linguistic markers, without relying on customers to declare their own situation. Every session generates a timestamped vulnerability assessment record, which is the audit trail Consumer Duty requires. EchoDepth provides the evidence and flags, and all vulnerability determinations remain with qualified staff.

See EchoDepth on a real customer interaction.

Submit a recording or transcript from a customer interaction. We return a full EchoDepth vulnerability analysis within 5 working days - free, no commitment.

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ICO registered ZB915633 · FCA Regulatory Sandbox · UK GDPR compliant · hello@cavefish.ai