Why simplify? – It’s better for everyone!

Why Simplify? This series explores how to make legally required information clear and accessible, covering regulations, commercial benefits, and consumer impact. It’s time to rethink communication in financial services.

Let’s be honest: financial services documents can be a real headache. Even the most educated among us have found ourselves rereading the same paragraph, still unsure what it means. Sometimes, we never quite get there at all.

So, why does this happen? Sometimes, it’s because legislation or regulation say we must use certain formats or phrases. Other times, regulations like the 2023 Consumer Duty require us to make sure every communication is genuinely understandable. How do we balance these sometimes-conflicting demands?

This series explores the big question: Why Simplify? We’ll look at the challenges of delivering legally required information in a way that’s clear and accessible for everyone. We’ll cover the regulatory landscape, the commercial upsides, and—most importantly—the benefits for consumers. It’s time to rethink how we talk to customers in financial services.

Making financial documents easier to understand isn’t just a nice-to-have. It’s essential for building trust, boosting engagement, and helping people make informed decisions.

Article 1: The Regulatory Imperative

If you’ve worked in financial services over the past decade, you’ll be very familiar with these terms:

  • transparency;
  • plain and intelligible language;
  • accessibility;
  • clear communications;
  • good outcomes

UK regulators have championed these principles for years. Accessibility rules for public sector bodies arrived in 2018. The Home Office’s 2020 Accessibility Standard recommends writing for a reading age of just nine. The Consumer Rights Act 2015 says written terms must be “plain and intelligible.” In 2019, the Treasury Select Committee suggested all financial communications should have a reading age of 11- to 12-years.

The Financial Conduct Authority (FCA) raised the bar again with the 2023 Consumer Duty. Now, firms must deliver “good outcomes” for consumers, which means clear, understandable communications that allow customers to make informed decisions.

But what does this mean in practice? Understandable to who? Not just understandable for bankers or lawyers—but for the real people signing up for these services. Regulators expect more than just disclosure; they want proof that customers truly understand what they’re agreeing to.

  • as of May 2024, about 48% of UK adults had some form of credit or loan
  • in 2011, 14.9% of adults in England had a reading age of 9–11

To comply with Consumer Duty, documentation must be clear for every one of those 48%. If a significant portion of adults read at a 9–11-year-old level, much of today’s documentation simply isn’t compliant.

But reading age isn’t the only factor. Engagement, accessibility, and diversity, equity, and inclusion (DEI) matter too. We’ll dive into those in future articles.

The Challenge of Mandatory Wording

Sometimes, the law requires us to include specific phrases. This can lead to information overload, which may negatively impact customer understanding. For example, some consumer credit documents are required to detail APR or representative APR. How useful is this information to the consumer? The inclusion doesn’t answer the most important question: “What will this cost me?” This is a clear signal that the government and the FCA need to resolve these conflicts in upcoming reforms. Being compliant with the consumer credit rules isn’t enough to ensure compliance with the more recent requirement of customer understanding.

The Path Forward

We’ve made progress towards clearer, more accessible financial documents—but there’s still a long way to go. As regulations evolve, firms must commit to simplifying language and cutting unnecessary complexity. Only by prioritising real understanding over legal box-ticking can our industry deliver the good outcomes consumers deserve.

On the 15th October 2025, we launched our new Financial Services Simplification report, developed in partnership with YouGov. The report explores how consumers respond to financial services communications and highlights the growing importance of clear, effective messaging – especially as regulatory expectations rise.

For more information about the report or to find out how we can help you please get in touch with the key contacts featured on this page.

Why Simplify? is a 3-part article series. Articles 2 and 3 will be published shortly.

Disclaimer

This information is for general information purposes only and does not constitute legal advice. It is recommended that specific professional advice is sought before acting on any of the information given. Please contact us for specific advice on your circumstances. © Shoosmiths LLP 2025.

 

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