Average investment product documents remain over 21,000 words long two years on from the FCAs Consumer Duty coming into force.

Under Consumer Duty rules, firms must prove that customers can understand their communications.

But many financial services firms have barely trimmed the length or complexity of their documents, according to Fairer Finance.

Average investment product documents are currently 21,523 words long. This compares to 22,666 words long for travel insurance documents and 17,121 words for Shakespeare’s Macbeth.

Travel insurance and investment terms and conditions were the products with the highest word counts, closely followed by home insurance policies (18,802 words).

The National Literacy Trust reports that 16.4% of adults in England have “very poor literacy skills”, classifying them as “functionally illiterate” and adding that reading information from unfamiliar sources or on unfamiliar topics could cause them problems.

These consumers with poor literacy skills are also deemed “vulnerable” by the FCA.

James Daley, managing director at Fairer Finance, said: “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 the Consumer Duty.”

Policy documents by word count

 Source: Fairer Finance, 26 August 2025