Amplifi | Blog

Introducing Amplifi & the Concept of Intelligibility

Written by Ewan Willars | Jul 9, 2025 12:19:23 PM

The FCA’s consumer duty requires that firms test and simplify their communications.

We've developed Amplifi to enable our clients to be able to test and improve their customer communications effectively, and efficiently.  

In this article:

  • What is Intelligibility?
  • Intelligibility in legislation and regulation
  • Readability vs intelligibility

 

What is Intelligibility and why is it important?

We have deliberately aligned Amplifi to the underlying regulation - in particular the Consumer Rights Act, and the Consumer Duty, and the underlying need for communications to be intelligible.

The Consumer Rights Act has been a fundamental underpinning to how firms must communicate with their customers for over 50 years. 

It requires that all contracts and regulated communications are expressed (in the words of the Act) in "plain and Intelligible language".

But what does Intelligibility mean in this context?

Intelligibility in legislation and regulation

"Intelligibility" has been defined by courts over the years, and in a legal sense it means that customers must be able to understand, and (crucially), be able to apply the information they are presented with.  In most cases this means the communications sent to customers must give them the information they need to be able to make an informed decision - to understand their risks, the costs of a product, and their rights and obligations, for example.

The Consumer Duty echoes this legal definition, and the requirement for intelligible customer communications.  In the words of the FCA's regulations, information to customers must:

  • meet their needs
  • be likely to be understood by all consumers, and
  • equip them to make informed decisions.

For a long time, measuring intelligibility without in-depth in-person studies was really challenging and costly to do. Instead, until recently, this usually involved testing how readable information was instead.  The weakness of this approach is that readability only really involves measuring sentence length, and how long words are, or how many syllables they have.  

Readability vs Intelligibility

Readability alone has been shown to be a very poor predictor of how likely text is to be actually understood.  

You can have very fluent, readable information, that is still conceptually highly challenging.  It might include difficult concepts, or short but unusual or technical words.  Or complex sentence structures that readers struggle with, using multiple sub clauses or semi-colons, for example.

So we built the world's first objective and repeatable measure of intelligibility. We did this with direct Innovation Support from the FCA.

We've found ways to test how conceptually difficult to understand written information is, as well as how readable it is. We cover all of those readability aspects involving grammar, sentence length and so on.  But we also look at conceptual difficulty.  We help clients to measure and avoid ambiguity - after all many words can mean different things in different contexts.  

We help to ensure client comms provide an adequate explanation of the more complex aspects.  And we can assess how various groups might understand things differently - for example, for readers with limited education and for who English may not be their first language, as compared to a high income, well educated reader, or someone with greater experience.

By doing what we do, we help clients reduce their compliance risk, and the risk of poor understanding outcomes for consumers.

Many existing methods and platforms may be great at measuring readability, but they can't predict understanding.  Amplifi can, and can be used quickly, and at scale.

Summary and actions

1) Your information has to contain the right information, be understandable, and help customers make better decision.
2) Amplifi tests true intelligibility, accurately and at scale.
3) By doing that we measure, mitigate and reduce compliance risk.

Some things you should be thinking about:

🤔 Consider what types of audience will be reading your content.

  • Are they sophisticated readers?
  • Might they need a little extra help understanding some of the more complex things you're trying to tell them?

😣 Think about where the reader might struggle and need a bit of extra help.  

  • Are you dealing with complex maths like interest rates or inflation?  
  • Are there technical terms they may need help explaining?  
  • Or are you dealing with a particularly emotive or challenging subject, such as debt?