The FCA's Consumer Duty Understanding Outcome requires firms to prove customers genuinely understand communications. A review isn't enough - you need a repeatable, evidenced process.

Subjective, reviewer-led approvals are inconsistent and unscalable. When something goes wrong, there's no audit trail to show what was checked or when.

The Motor Finance ruling proved that technically accurate disclosures can still fail the intelligibility test. Regulators now expect intelligibility to be measured and evidenced.