ISO 22458 Clause 5
Clause 5 applies inclusive design to every consumer touchpoint - contact channels, information, sales, contracts, payments, billing and complaints.
ISO 22458 Clause 5 - Inclusive Design
Clause 5 is the longest clause in the standard and the most operationally demanding because it covers everything the consumer actually sees and interacts with. The principle is simple - inclusive design considered at every stage and every touchpoint, with the explicit aim of reducing barriers rather than creating them. The detail is where the work sits, and where most existing services have gaps that only become visible when someone walks through the customer journey from a vulnerable consumer perspective.
Inclusive Service Design - ISO 22458 Clause 5.1
The general requirement of Clause 5 is that the organisation designs an inclusive service. The standard sets out six things this design must achieve - it must be accessible to and usable by the greatest number of consumers possible, involve consumers in service design, protect people in vulnerable situations, avoid unfair penalties, minimise the risk of harm caused by the organisation's actions or omissions, and assess the positive and negative impacts of the service on consumers in vulnerable situations.
The phrase "or omissions" is significant. A service that does not actively cause harm but fails to anticipate the needs of someone who is hard of hearing, working in a second language or recently bereaved is still capable of causing harm by what it does not do. Inclusive design is about closing those gaps deliberately rather than leaving them to chance.
Touchpoints - ISO 22458 Clause 5.2
The standard lists seven categories of touchpoint that need to be considered for inclusive design:
- consumer contact channels
- consumer information
- sales and contracts
- payments and billing
- cancellation
- complaints and disputes
- service environment
Each of these is a place where a consumer in a vulnerable situation can either be supported or pushed away. A useful exercise during implementation is to map the actual customer journey against these seven categories and check that inclusive design has been applied at each one. The F-Q100 Inclusive Design Impact Assessment is intended for exactly this purpose.
Understanding Consumer Vulnerability - ISO 22458 Clause 5.3
Inclusive design works best when it is informed by a real understanding of the consumer base, not a guess. Clause 5.3 sets out four mechanisms - research and mapping of the customer base (demographics, age profiles, languages, internet access, urban/rural split), stakeholder partnerships with specialist organisations representing groups such as people who are disabled, experiencing abuse, or living with dementia, terminal illness or debt, engagement with consumers who have lived experience of vulnerability, and ongoing monitoring of customer satisfaction, feedback and complaints.
The key is that some of this insight must come from outside the organisation. An internal review of complaints data is useful but not sufficient on its own.
Consumer Contact Channels - ISO 22458 Clause 5.4
Different contact channels suit different people at different times. The standard requires the organisation to offer a range of free, easy-to-access contact channels so consumers can choose their preferred method. Choice on its own is not enough - awareness of what each channel is for, hours of operation, charges where applicable, and any additional assistance available all need to be communicated.
Telephone services need to be simple to navigate, with clear exit routes from automated systems, slow and clear automated voices, enough time for delayed responses and additional assistance such as voice-activated systems, hearing loops or alternative language options. Online services need to work for people with visual impairment (text alternatives to images, large format, appropriate colour contrast), learning difficulties or cognitive impairments (simpler language, alternative formats, clear page layouts) and manual dexterity impairments (keyboard navigation rather than mouse-only).
Website accessibility against recognised standards such as WCAG 2.2 is the practical baseline most organisations work to. The F-Q104 Website Accessibility Review records this work and provides an audit trail.
Consumer Information - ISO 22458 Clause 5.5
All information provided to consumers - verbal, printed or online - must be clear, accurate, relevant and timely. Clear means plain language, free of unnecessary technical terms. Accurate means factual, truthful and not misleading by omission or by being out of date. Relevant means appropriate to the individual's circumstances. Timely means provided when it is most useful to inform decisions.
Key information specifically - terms and conditions, prices, interest rates, fees, payment deadlines, cancellation rights, complaint and dispute resolution details - has to stand out, be available in alternative formats on request (braille, large print, audio, different language), be provided in printed text where verbal information is given, use simple visual representations where the underlying detail is complex, and include reasonable steps to confirm the consumer has received and understood it.
Sales and Contracts - ISO 22458 Clause 5.6
Where the organisation provides sales advice, a sales policy is required setting out good practice when selling to consumers in vulnerable situations. The standard flags several specific risks - sales systems based on commission and incentives, sales visits in the consumer's home, and the absence of identification of who advised on a specific transaction. Mystery shopping, regular review of sales advisor behaviour and a written code of conduct backed by training are typical controls.
Contract terms must not unfairly disadvantage consumers in vulnerable situations through higher rates and charges, minimum purchase quantities or barriers to switching. The CC-CV1 Code of Conduct includes the public sales-conduct statement, and the PP-1-17 procedure references the sales arrangements internally.
Payments and Billing - ISO 22458 Clause 5.7
A range of flexible payment options is required to suit consumers in different circumstances - including those without a regular monthly income, a bank account, a debit card or internet access. Terms of those options need to be transparent. Where a consumer fails to pay, the organisation is required to act responsibly, offer realistic options and consider whether the missed payment is itself a sign of vulnerability rather than reaching straight for penalties or termination.
Billing needs to be clear, with easy ways to query items, understand how the bill was calculated and access alternative formats.
Complaints and Disputes - ISO 22458 Clause 5.8
The complaints handling system must be highly visible and accessible. Consumers should be able to find it easily, use it without unreasonable effort, and get an early-stage response that prevents harm escalating. Frontline staff need the training and the authority to resolve issues at first contact wherever possible. Where dispute resolution is needed, the route to it should be clear and not buried at the bottom of a long terms-and-conditions page.
The way to test inclusive design is to walk through your own service as if you were a customer with a problem. Pretend you have just been bereaved. Pretend English is not your first language. Pretend you are using a phone with cracked glass. If your contact page is buried three clicks deep, your phone menu has fourteen options before you reach a person, and your complaints process needs you to log in to a portal to get started, you have built a service that excludes people.
None of this is hard to fix, but you have to actually do the walk-through.
For Clause 5 I look for evidence that the organisation has actually mapped its touchpoints and assessed each one. The Inclusive Design Impact Assessment is the obvious source. I want to see it covers the seven touchpoint categories listed in 5.2 and is dated within a reasonable timeframe rather than reflecting a state of the service from several years ago.
I also check the website accessibility review and the sales and complaints arrangements. For organisations that do not provide sales advice the sales section may not be relevant, but they need to have considered it and recorded that conclusion. For complaints I want to see the route from website to resolution timed and tested, not just described in the procedure.
Where contracts and billing materials are part of the service, those go in scope as well. Bills written in a way that consumers cannot understand are a Clause 5.5 finding even if they are technically accurate.
Practical Compliance Guidance
Where IMS1 is in use, Clause 5 is reflected through Section 4.1 (Control of Enquiries and Sales), Section 4.4 (Management of Change, where the inclusive service design step is referenced) and Section 5.1 (Customer Satisfaction). The inclusive design impact assessment, website accessibility review and the sales and complaints arrangements documented in PP-1-17 supply the operational evidence.
The alphaZ documents below cover the inclusive design tools, accessibility review and supporting policies that Clause 5 requires.
| alphaZ document | How to use it |
|---|---|
| ISO 22458 Toolkit | Full document set for an ISO 22458 inclusive service management system, including the inclusive design tools, accessibility review and supporting procedures. |
| F-Q100 Inclusive Design Impact Assessment | Form for assessing whether a new or existing service is set up to be accessible across the seven touchpoint categories. |
| F-Q104 Website Accessibility Review | Form for recording a structured review of website accessibility against recognised guidance such as WCAG. |
| PP-1-17 Vulnerable Consumer Procedure | Internal procedure that sets out the operational arrangements for inclusive service design, sales conduct and complaints handling. |
| CC-CV1 Code of Conduct - Vulnerable Consumers | Publicly shareable code of conduct including the sales conduct, third-party representatives and interruptions to essential services policy statements. |
| GG-1-17 Consumer Vulnerability Guidance | Plain-language general guidance for staff awareness, useful as the basis for inclusive design discussions with service teams. |
Note - all the above files can be downloaded with an alphaZ subscription.
Frequently Asked Questions
UK Legislation
The following UK legislation is directly relevant to ISO 22458 Clause 5. Organisations outside the UK should identify the equivalent legislation applicable in their jurisdiction.
- Equality Act 2010
- Consumer Rights Act 2015
- Consumer Protection from Unfair Trading Regulations 2008
- Public Sector Bodies (Websites and Mobile Applications) (No. 2) Accessibility Regulations 2018
