‘Two years on from the introduction of Consumer Duty and many policy documents and T&Cs from across financial services are still far too complex and lengthy,’ says managing director

Travel insurance policy wordings remain among the longest in financial services with an average of 22,666 words, despite the FCA’s Consumer Duty rules requiring firms to make communications more understandable for customers.

This is according to new analysis published by consumer group Fairer Finance on 26 August 2025, which showed that the average travel insurance policy document has 22,666 words – longer than Franz Kafka’s novella The Metamorphosis, which has around 22,000 words, depending on the edition.

Home insurance terms and conditions (T&Cs) averaged 18,802 words, while car insurance policies ran to around 16,504 words, Fairer Finance found.

James Daley, managing director at Fairer Finance, said the lack of progress in reducing policy word counts risked undermining customer understanding.

He explained: “Two years on from the introduction of Consumer Duty and many policy documents and T&Cs from across financial services are still far too complex and lengthy.

”The longer these documents are, the less likely consumers are to engage with them and the harder they are for customers to understand.

“Helping consumers understand the complexity of these products is essential if we’re to create a fair financial services market which people can trust and have confidence in.”

The FCA’s Consumer Duty came into force on 31 July 2023.

Daley continued: “We know from working with dozens of firms in the sector that it is possible to shorten these complex documents and make them clear and accessible for customers. But many firms have not started the hard work that Consumer Duty requires them to do.

”The grace period is now over – and we expect the regulator to start holding companies to account where they are ignoring Consumer Duty.”

The same length as Macbeth

Fairer Finance’s research found that travel insurance and investment documents were the longest on average, at more than 21,000 words each.

Home insurance was the third highest, with policies averaging close to 19,000 words. By comparison, a typical bank account agreement came to 15,859 words – almost the same length as Shakespeare’s classic tragedy Macbeth.

In terms of why these word counts are proving so vital to customer understanding, Fairer Finance cited data from the National Literacy Trust website which identified that 16.4% of adults in England had very poor literacy skills, while similar government figures suggested that around one in seven adults had the reading skills of a child aged nine to 11.

To help improve consumer understanding of insurance products, Fairer Finance has developed a document analyser tool, which highlights jargon, long sentences and layout issues within policy documentation, as well as benchmarks paperwork against peer products.

The consumer group said it planned to expand the tool to include a jargon buster, to help firms further improve customer comprehension.

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