The Comprehension Standard
Consumer Understanding
Insurance firms have historically measured communication success by whether information was provided — not whether it was understood. The Consumer Duty reframes the obligation entirely: firms must evidence that customers can make effective, timely, and informed decisions. 82% of customers reported no improvement in insurer communications since the Duty came into force.
The structural move is to replace the disclosure test (“did we tell them?”) with a comprehension test (“can they act on what we told them?”) — and to build the feedback mechanism that makes comprehension visible before harm occurs:
Testable standardsDefine what comprehension means for each significant communication. For a policy summary: can the customer identify the three most consequential exclusions? For a renewal: do they understand what changed? The standard must be specific enough to test against, not a vague aspiration to be clear
Pre-deployment testingTest with real customers from the actual target market — including those with lower literacy, limited digital confidence, or English as a second language — before communications go live. This is the structural change: comprehension becomes a gate, not a retrospective measure
Signal integrationPost-deployment, connect the signals that indicate comprehension failure — call volumes about specific documents, journey abandonment at information-heavy points, complaint themes about confusion, claims disputes citing coverage misunderstanding — into a feedback loop that triggers revision
Significant customer communications have defined comprehension standards with measurable success criteria
Pre-deployment testing is conducted with representative customer segments, including vulnerable cohorts
Post-deployment signals (call drivers, complaint themes, journey analytics) feed back into communication revision
Comprehension scores are tracked over time and reported to product governance committees
A health insurer tested its policy summary with a sample of actual customers and found that only 31% could correctly identify whether their policy covered mental health treatment. The document was written at a reading age of 17. They rewrote it at reading age 12, restructured it to lead with exclusions rather than benefits, and retested: comprehension of the mental health exclusion rose to 74%. The Flesch-Kincaid score improved, but it was the structural change — leading with what the product does not cover — that drove the comprehension shift.
A home insurer noticed that 15% of all inbound calls in the first month of a policy were customers asking what their excess was. The information was on page 8 of the policy schedule. Moving it to the confirmation email — three lines, no jargon — reduced those calls by 60%. The communication had been compliant throughout; it only became effective when the comprehension signal was connected to the design.
- Common failure modes
The primary failure mode is equating comprehension with readability. Flesch-Kincaid tells you whether words are short and sentences are simple; it says nothing about whether the customer understood the consequence of what they read. A second is testing only with digitally confident, English-speaking customers who do not represent the actual base. A third is establishing the standard but not enforcing the gate — allowing communications to launch on commercial timelines despite failing the comprehension test.