Increasing customer understanding by simplifying policy language
Ensuring compliance with financial regulations must be at the core of insurance policy language, but legalese can alienate customers. Is it possible to balance compliance with plain English? Chloe Fox investigates
Travel insurance plays a crucial role in protecting travellers, yet the policies meant to offer peace of mind often leave customers confused. Industry leaders agree that despite best intentions, simplifying policy language remains a challenge shaped by regulation, legal caution, and product complexity.
Jackie Mondelli, Chief Marketing Officer at US comparison site Squaremouth, highlighted a major barrier: “One of the main challenges in simplifying insurance policy language is that it’s regulated at the state level. Each state has its own legal requirements, often mandating specific language and disclosures that can’t be altered. This limits how much insurers can streamline.”
Adding to the complexity is the increasing diversity of travel insurance products. “Travel insurance is becoming less of a one-size-fits-all product,” Mondelli said. “With specialised policies for cruises, adventure travel, budget trips, and flexible plans, capturing all the necessary caveats into a single description, while remaining accurate and compliant, is increasingly difficult.”
The reason it often isn’t prioritised is that most people don’t claim – so they’re blissfully unaware their policy doesn’t meet their needs
David Allison, Head of Intermediary Consultancy South at Insurance Compliance Services, agreed. “Tradition, legal departments, and a fear of making language too broad are major barriers. Insurers are understandably cautious – getting this wrong could increase claims, hurt profitability, and ultimately cost market share. Drafters of policy wordings are often too engrained in the technicalities.”
A regulatory landscape in transition
Despite these challenges, regulatory frameworks are evolving to encourage clearer communication. Mondelli pointed to growing support: “Regulators are increasingly backing efforts to simplify insurance communications, but legal and compliance requirements still create limits.”
In the UK, notably, the Financial Conduct Authority’s (FCA) Consumer Duty came into force on 31 July 2023. This mandates that firms proactively deliver good outcomes for customers, including ensuring that communications help them to understand products and services. The FCA emphasised that “consumers can only be expected to take responsibility for their financial decisions where firms’ communications enable them to understand their products and services, their features and risks, and the implications of any decisions”.
The FCA expects travel insurers to overhaul their policy wording and documentation – making them more consumer-friendly via clearer language, design, and signposting. AllClear Travel Insurance, for instance, has introduced colour-coded booklets and prominent pointers to clarify coverage versus exclusion. It targets older or vulnerable customers and routinely monitors feedback to rework confusing elements.
The Association of British Insurers (ABI) has also partnered with Fairer Finance and Plain Numbers to enhance language clarity and help consumers select appropriate policies.
Technology is also driving progress, with digital platforms enabling continual improvements. Online policy documents have become clearer than they were a decade ago, and insurers are increasingly using artificial intelligence (AI) tools to simplify wording by shortening text, reducing formality, and presenting information in bullet points – changes that also cut drafting time significantly.
However, complaints to the UK’s Financial Ombudsman Service (FOS) rose to 4,466 in 2023/24 – a 19% increase from the previous year – with many relating to medical non-disclosure, insufficient medical assistance abroad, and claims over delayed or lost luggage. This underscores persistent consumer confusion despite improvement efforts.
Plain language as a business imperative
Clearer policy wording is increasingly being recognised not just as a regulatory necessity, but as a business opportunity.
James Daley, Managing Director of Fairer Finance, stated: “It should be both a business imperative and a regulatory one. The reason it often isn’t prioritised is that most people don’t claim – so they’re blissfully unaware their policy doesn’t meet their needs. But this is a very short-term view.”
He argued that effective communication can build lasting customer trust and loyalty. “If insurers can communicate clearly, they’re more likely to retain customers. But if they can’t see the business case, they now have a clear regulatory obligation to communicate clearly under the Consumer Duty.”
Lauren Gumport, Vice President of Communications and Brand at Faye, echoed this: “Travel insurance should be easy to understand and digestible. Travellers should be able to review coverage options and feel well informed, rather than confused. At the end of the day, travel is built on trust – and insurance is about protecting what matters. If consumers can’t understand how they’re protected, how can they trust you?”
There’s been real progress on language simplification, but length remains a major issue
Further support for simplification comes from the British Insurance Brokers’ Association’s (BIBA) 2020 manifesto calling for plainer English policy wordings – highlighting that even standard travel policies could exceed 20,000 words, replete with jargon few can parse – and urging the industry to adopt simpler, more user-friendly forms.
Daley added that good design with adequate spacing, clear headings, and use of colour and images was crucial. “Research from Fairer Finance shows that typical policy documents require reading ages well beyond many UK consumers; one in six has a reading age of 11 or lower.”
Whose responsibility is it anyway?
When it comes to bridging the expectation gap, the question of responsibility remains contentious.
Daley argued the onus lay with insurers. “These are complex policies, and there’s a big expectation gap. If insurers explain the benefits and limitations clearly – across multiple channels – then yes, the responsibility can shift to the customer. But right now, most insurers aren’t close to that point.”
Gumport agreed: “Many providers aren’t investing enough in speaking customers’ language. We work hard to make our coverage and care easily digestible – via our website and app – so travellers feel informed rather than overwhelmed.”
Strategies to bridge the gap
To better meet customer needs, insurers are turning to layered documents, more intuitive design, and simplified messaging.
Mondelli noted: “Many insurers now use layered policy documents. These start with a clear summary of key features – coverage limits, deductibles, major exclusions – followed by full legal text for those who want more detail.”
Language tone and structure matter. Gumport explained: “We communicate our protection plans into a few buckets: your health, your stuff, your trip, and add-ons. We also clearly show access to our 24/7 support team and app-based tools.”
Allison added: “There’s been real progress on language simplification, but length remains a major issue. Policy documents can run to 50-plus pages – who’s going to read that?”
Even plain English faces a limit when documents are too long, making key exclusions easy to miss – leading to surprising claim denials. “The length alone can put off readers,” Allison noted, “so customers may miss key exclusions and face surprises when claims are denied.”
The role of brokers
While digital tools improve access, brokers remain essential – particularly for vulnerable segments.
Michael Camacho, President of CSI Brokers and Past President of the Travel Health Insurance Association of Canada, sees brokers as vital for older travellers or those with health conditions. Brokers help explain differences between insurers, interpret underwriting questionnaires, and clarify the importance of stability periods.
He noted that Canadian regulators demanded fairness in treatment, requiring robust broker training and clear marketing and point-of-sale information.
However, innovations are emerging: Canadian brokerage AwayCare has partnered with Aerogami to deliver mobile-
friendly policy documents, ID cards, and claims support. Others offer self-serve portals so travellers can manage coverage easily. Camacho highlighted this as a meaningful improvement in accessibility.
Many providers aren’t investing enough in speaking customers’ language
Legal and regulatory examples supporting clarity
UK regulations also support simplification. The FCA requires travel firms to supply Insurance Product Information Documents (IPIDs) – clear summaries of key features and exclusions – to aid consumer understanding.
Further, FCA rules now oblige firms to signpost consumers with pre-existing medical conditions to a specialist provider directory if they’re declined coverage, face exclusion, or receive heightened premiums. Firms must explain why this signposting occurs and the benefits of specialist cover. The Insurance Conduct of Business Sourcebook (ICOBS) 6A.4 rules require firms to provide clear, prominent information about medical cover directories, ensuring explanations are consumer-centric and avoiding confusing language or discouragement.
In claims handling, the FCA reminds firms of their obligations under the Consumer Duty: claims must be handled promptly, fairly, with customer support, clear guidance, and timely updates. However, in travel insurance, claims often involve emergencies – so poor service can cause real harm. Many firms still need to improve clarity on coverage, especially where high rejection rates or walkaways indicate poor customer understanding.
Many firms still need to improve clarity on coverage, especially where high rejection rates indicate poor customer understanding
Conclusion: language as the next battleground
Travel insurance is by nature complex – but complexity need not equal confusion. As regulatory guidance evolves and the industry realises the power of consumer trust, plain-language policies are emerging as both a compliance necessity and a commercial advantage.
From the FCA’s Consumer Duty to ABI and BIBA campaigns, regulatory and trade bodies emphasise clear communication. Insurers adopting layered documents, clear design, digital enhancements, AI tools, and broker support are seeing benefits in trust and satisfaction.
Ultimately, improved clarity isn’t just about reducing complaints – it’s about empowering travellers to understand how they’re protected. In an era where trust may be the most valuable currency, making policy language clear is perhaps the ultimate competitive edge.
November 2025
Issue
In this issue of ITIJ we look at current travel patterns to and from the US and Europe, take a close look at the Italian healthcare system, and examine how insurers are adapting policies and coverage to manage weather-related challenges.
Chloe Fox
Chloe Fox is an Editorial Assistant for Voyageur Group, joining in 2024. She writes for ITIJ and AirMed&Rescue, covering a range of topics including international travel and health insurance, medical assistance provision, and air medical transportation. Chloe holds a BA (Hons) in English and an MA in English Literature from the University of Bristol.