Children and Vulnerable Users

What the Code says

The Code of Conduct requires that we “protect the vulnerable from exploitation” and “consider the impact of our work on all audiences, including those who may be more susceptible to harm.”

The Code of Practice adds that we should “consider whether communications might be seen by vulnerable audiences” and “avoid exploiting credulity, lack of knowledge, or anxiety.”

Understanding vulnerability

Vulnerability isn’t a fixed category — it’s contextual and situational:

Who might be vulnerable?

• Children and young people — lack of experience and critical evaluation skills
• Elderly people — may have cognitive changes, be isolated, or face health concerns
• People with mental health conditions — anxiety, depression, addiction
• People in financial difficulty — debt, job loss, money worries
• People with health concerns — illness, diagnosis, caring responsibilities
• People in grief or crisis — bereavement, divorce, trauma

Situational vulnerability

Anyone can be vulnerable in certain situations. A confident professional might be vulnerable when newly diagnosed with illness. A financially secure person might be vulnerable after job loss.

Advertising to children

Children are protected across all advertising, but rules are strictest in specific sectors:

General principles

• Don’t exploit children’s inexperience or credulity
• Don’t encourage children to pester parents
• Don’t suggest products make children superior
• Don’t show unsafe behaviour that children might copy

Sector-specific rules

• Gambling — cannot appeal to under-18s at all
• Alcohol — cannot appeal to under-18s; people must appear 25+
• HFSS food — significant restrictions on advertising to children
• Age-restricted products — careful targeting required

Digital concerns

• Children use digital media heavily
• Age gates and verification aren’t foolproof
• Influencer content may blur advertising lines
• Data collection from children is heavily restricted

Financial vulnerability

Financial services advertising must be particularly careful:

FCA expectations

The FCA expects firms to design products, services and communications with vulnerable customers in mind. This includes marketing copy.

What to avoid

• Targeting people in financial difficulty with high-cost credit
• Creating pressure to make quick financial decisions
• Exploiting anxiety about debt or money
• Oversimplifying complex financial products

What to include

• Clear information about costs and risks
• Signposting to debt advice where relevant
• Encouragement to seek advice if unsure
• Accessible explanations of complex terms

Health-related vulnerability

Health advertising requires particular sensitivity:

Don’t exploit health anxieties

• Avoid creating fear to sell products
• Don’t suggest products offer miracle cures
• Be honest about what products can and can’t do
• Don’t discourage people from seeking medical advice

Be careful with weight and body image

• Don’t target people with eating disorders
• Avoid “before and after” imagery that creates unrealistic expectations
• Don’t suggest people are inadequate because of their weight

Mental health considerations

• Don’t stigmatise mental health conditions
• Be careful with content that could trigger harm
• Include signposting to support services where appropriate

Cognitive accessibility

Accessibility isn’t just about physical disabilities — consider cognitive accessibility too:

Plain language

• Use short sentences and simple words
• Explain technical terms
• Avoid jargon and acronyms
• Use active voice

Clear structure

• Break content into logical sections
• Use headings to guide reading
• Put important information first
• Use bullet points for lists

Consider different needs

• Dyslexia — clear fonts, good spacing
• Low literacy — simpler vocabulary, visual aids
• Cognitive impairment — step-by-step instructions
• English as additional language — avoid idioms

Using ethical judgement

Beyond rules, use professional judgement:

Questions to ask

• Who is likely to see this content?
• Could any of them be vulnerable?
• How might a vulnerable person interpret this?
• Does this content exploit anxieties or insecurities?
• Would I be comfortable if a vulnerable family member saw this?

When to push back

If you’re uncomfortable with content that might exploit vulnerable people, raise your concerns with the client. The Code of Practice supports refusing work that conflicts with ethical standards.

Positive framing

You can often achieve commercial objectives while being responsible. Focus on genuine benefits rather than exploiting fears. Build trust rather than pressure.

Summary

Protecting vulnerable audiences isn’t just a regulatory requirement — it’s a professional and ethical responsibility. Consider who might see your content, how they might be affected, and whether you’re exploiting vulnerabilities or providing genuine value.

Good copywriting doesn’t need to exploit vulnerability. Clear, honest, accessible communication serves both commercial objectives and vulnerable audiences.