Improving readability in the face of the Consumer Duty

The United Kingdom’s FCA  Consumer Duty has transformed the landscape of marketing material. With a focus on consumer-centricity and transparency, businesses must ensure their marketing content is easily comprehensible to the average consumer.

Readability, therefore, has become a central concern. And there’s a lot of room for improvement. The 2023 Readability Report by Communications and Content[1] used a readability score to understand the complexity of investment content when compared with other written material. The higher the score, the harder the content is to read. It found that:

• Investment content[2] achieved a poor readability score (12.3), which is closer to complex academic research papers (13.1) than the accessible financial media (11.1).
• Converting the readability scores into a reading age, investment content (at 17.9yrs) is comparable to reading the UK’s A level study materials.
• A sample of recent past papers shows that it’s significantly easier to understand an economics A level exam paper (8.0) than investment content (12.3).

In this article, we’ll delve into what the consumer duty means for readability, explore readability scores like Flesch-Kincaid, and discuss practical approaches to enhance readability in your marketing material.

Readability and the Consumer Duty

The Financial Conduct Authority (FCA)  has provided considerable guidance about tailored communications in accordance with the Consumer Duty, including[3]:

1. When communicating about the product, firms should consider the characteristics of the consumers within its target market and tailor communications to meet their information needs.
2. For mass marketing products, firms should take into account research relating to poor or low levels of numeracy and literacy and communicate information in as simple a way as possible to support understanding for these customers.
3. Firms should take particular care when communicating with consumers in vulnerable circumstances, taking account of their needs.

While the FCA acknowledges that it can be challenging to simplify communications about financial products and services, firms are expected to take reasonable steps to support understanding.

Taking an holistic approach to readability across all marketing assets is a relatively straightforward way to improve – and demonstrate you’re taking steps to improve customer understanding.

Readability refers to the ease with which a piece of writing can be understood by its intended audience. It involves assessing factors like sentence structure, word choice, and overall complexity to ensure that the content is clear, accessible, and effectively conveys its message. This is distinct from legibility (also key in marketing communications) which concerns how well the visual characteristics of the text can be recognised by the reader.

Using readability scores to improve readability

Readability scores are algorithms that assess the complexity of a piece of writing based on factors such as sentence length and syllable count. These metrics generate a numerical score that reflects the readability level of the text. Often, these are translated into a US grade level such as “4th grade” or “10th grade”[4]. The lower the grade, the easier the text is to understand.

The most common formula is the Flesch-Kincaid readability formula – available in most modern versions of Microsoft Word – but there are many which can be used in difference circumstances.

Marketing material should aim for a readability score that matches the educational background of the target audience. The Communications and Content readability report recommends that “…investment content should be achieving readability scores of no more than 11.1 [~16 year old reading age]” which is about the same as the average investment publication in the mainstream media[5]. Aiming to meet a similar readability standard to media reports in your industry can be a useful, and realistic, goal to start with.

Of course, more complex or specialised products may require more complex language. Gaming the score by using simpler words may not assist customers, and using less common words that more accurately convey your message can result in better understanding. Readability scores are only indicative, not the final word.

By using tools that automatically calculate readability scores, such as Red Marker, businesses can ensure that their content aligns with their audience’s educational background and complies with the Consumer Duty readability expectations.

Practical approaches to improve readability

To enhance the readability of marketing material following the implementation of the UK Consumer Duty, consider the following practical approaches:

1. Reduce syllables and sentence length: Use plain language that is clear and straightforward. Avoid jargon, technical terms, or complex language that may confuse consumers – unless really necessary
2. Break content up: Use subheadings, bullet points, and short paragraphs to make the content easier to scan. This approach helps consumers find the information they need quickly.
3. Use visual elements: Incorporate visuals like images, infographics, and charts to complement the text. Visuals can enhance understanding and engagement.
4. Clear call to action: Ensure that your CTA is concise, specific, and prominently displayed. It should tell the consumer exactly what to do next.
5. Test with your audience: Before finalising marketing material, consider conducting readability tests with representative members of your target audience. Their feedback can provide valuable insights into areas that may need improvement.

1. David Butcher, The 2023 Readability Report: Investment content continues to test its readers, October 2023 (link) p3.
2. Investment content comprised three prominent or promoted written items of content from 22 award winning companies at the 2023 Fund Manager of the Year Awards. See page 22 of the 2023 Readability Report.
3. United Kingdom Financial Conduct Authority, FG22/5 Final non-Handbook Guidance for firms on the Consumer Duty, July 2022 (link) at 8.30 – 8.38.
4. Most of the widely used tests such as Flesch-Kincaid Grade Level, Gunning-Fog Index, Fry Method and SMOG method output grade scores based on the United States schooling system. Abid Ismail et al note that “there is a strong need to develop country specific grading mechanism with respect to readability.” (see Abid Ismail et al, Connect the dots: Accessibility, readability and site ranking – An investigation with reference to top ranked websites of Government of India, Journal of King Saud University – Computer and Information Sciences, Volume 31, Issue 4, 2019, Pages 528-540, ISSN 1319-1578, https://doi.org/10.1016/j.jksuci.2017.05.007.(https://www.sciencedirect.com/science/article/pii/S1319157816301550)
5. David Butcher, The 2023 Readability Report: Investment content continues to test its readers, October 2023 (link) p9.