What is intelligibility?
It’s not just about being readable. It’s about being understood.

What it means
“Able to be understood by the target audience, including the context and the consequences of the information to the reader.” (FCA Consumer Duty)
The term intelligibility is defined in legislation and case law. It goes far beyond tone or readability, it’s about consumer understanding in real-world contexts.
The European Court of Justice (CJEU) ruled that intelligibility means a document must:
- Enable consumers to understand the meaning of terms and their practical implications
- Allow an average consumer to evaluate the economic risks and consequences
- Be presented in a way that supports transparency and informed decision-making
What's expected
What Regulators Expect
The FCA’s Consumer Duty (PRIN 2A.5.3) makes this a formal requirement. "A firm must support retail customer understanding so that communications;"
- Meet the information needs of customers
- Are likely to be understood
- Help customers make effective, timely, informed decisions
Testing intelligibility
The Real Challenge
Despite its importance, intelligibility is hard to test:
- Traditional readability tools (like Flesch-Kincaid) don’t consider context, consequences, or complexity of meaning
- There’s no universal method to assess intelligibility at scale
- Firms often rely on manual reviews or checklists, which aren’t scalable or objective
How we can help
Where Amplifi comes in
Amplifi was built to make intelligibility measurable, trackable, and auditable. We go beyond surface-level checks. Our platform uses behavioural insights and FCA-aligned models to:
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1. Assess
Scores documents using the Amplifi Intelligibility Score, based on real-world research
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2. Prioritise
Flags high-risk sections, terms, or messages that may trigger misunderstanding
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3. Simplify
Provides guided suggestions and AI-powered rewrites built for regulated content
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4. Test
Tracks revisions and compare scores to demonstrate improvement
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5. Report
Generates compliance-ready reports for internal teams or regulators
Setting the standard
Building the Intelligibility Standard
Amplifi is working with regulators, academic partners, and industry stakeholders to define a clear Intelligibility Standard.
We're committed to making this framework more accessible over time, and collaborating with organisations who share our goal of building a fairer, more transparent communication ecosystem