We're writing PDSs for a reader who doesn't exist
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Mayflower PDS Managers Roundtable
Most product disclosure statements technically satisfy the regulatory standard. They are clear, concise and effective - on paper. And yet complaints are rising, trust is declining and remediation costs keep climbing.
Our May PDS Managers Roundtable heard a pointed explanation from guest speaker Mia Lander, a clinical psychologist with deep corporate communication experience: we are designing for an ideal reader, and that reader almost never exists - least of all at the time that a disclosure is actually read.
The reader we imagine vs the reader we have
The ideal PDS reader is calm, focused, reading sequentially with high working memory and plenty of time. The actual picture looks quite different. One in five Australians have experienced a mental health disorder, 17% have had an anxiety disorder, and when anxiety is active, the brain shifts from reasoned decision-making to reactive self-protection.
Add an ageing population, the cognitive squeeze of what Mia called the "sandwich generation" - people simultaneously caring for children and elderly parents - and the reality that one in five Australians are neurodivergent, and you have an audience whose reading capacity is under significant pressure before they even open the document.
When do members really read their PDSs? We all know the truth: when they want to make an insurance claim, when they are upset about something, or when their partner has died, and they need to understand what happens next. In all three situations, they are in a high-stress state with reduced cognitive capacity. That is when your carefully crafted disclosure lands in front of a real human being.
Neurodivergent users as the canary in the coal mine
Mia's core argument was that neurodivergent members are not a separate audience requiring accommodation, they are your early warning system. When content is hard for someone with ADHD, dyslexia or ASD, it is usually hard for a lot of people reading under pressure. Fix the disclosure for them, and you improve it for everyone. Higher effort always produces lower capability, regardless of diagnosis.
The CLEAR model
Mia introduced a practical framework synthesised from the literature. CLEAR: Chunked, Layered, Explicit, Accessible, Risk-forward.
Chunked means one idea per section, short sentences, white space - if a member skim-reads it, do they still get the point?
Layered means summary first, details below, optional examples last - can someone get the basics in 30 seconds?
Explicit means clear rules with no vague language, would two readers come away with the same meaning?
Accessible means plain language and sans-serif fonts, readable when tired or stressed.
Risk-forward means consequences are visible upfront, not buried three paragraphs in.
The before-and-after example was instructive. Dense legal prose that buries the risk across multiple clauses, versus: "We will NOT pay your claim if you did not tell us about a condition, or your treatment is not covered." Same information, vastly different outcome for a member reading under pressure.
What practitioners in the room said
The discussion that followed was insightful. A few things stood out.
On legal negotiation: be clear on who owns what. Legal owns technical accuracy and product owns member comprehension. Conflating the two is where language gets stuck. Bullet points and paragraph breaks can get you a long way. Nested clauses and overly long sentences continue to be an issue. Removing semicolons and "and/ors" from lists by writing a cleaner lead-in sentence is a small change that meaningfully improves readability without triggering legal objections.
On insurance guides specifically: the source policies are often written in archaic language and you are fighting the readability battle before you have even started. Working directly with the insurer from the beginning, rather than trying to translate their language at the end, changes the outcome significantly. Welcome letters were flagged as particularly difficult due to rules around cover start dates, where the member often does not know exactly when their cover begins, with consequences that only become apparent at claim time. Risk-forward language here is not optional; it is the difference between a smooth claim and a complaint.
On consumer testing: the Life Insurance Code of Practice requires it for retail products, but not for group insurance. Several people in the room felt that gap needs to close. One fund noted they have implemented an accessibility overlay across their website with reading rulers, adjustable fonts, spacing, all at a relatively low cost. It works, there has been no controversy and it’s an easy way to get the ball rolling on ‘accommodations’ without making a big fuss.
On AI tools: at least one attendee had experimented with using AI to generate plain-English alternatives to dense PDS clauses. The consensus was that it is a useful starting point, not a finished product (the output needs review against legal accuracy) but as a way of seeing the possible, it is worth trying.
The regulatory constraints are real: eight-page PDSs, nine-point minimum font, prescribed wording that was never designed with accessibility in mind. There is an argument to be made to ASIC, and the group agreed someone needs to be making it. But within the constraints that exist today, there is still room to move to improve readability for all our customers.
Key takeaways
Disclosures are almost always read under stress. Design for that, not for the ideal conditions that rarely exist.
One in five Australians are neurodivergent. If your disclosure is hard for them, it is likely hard for many members reading under pressure.
Use the CLEAR model as a practical checklist: Chunked, Layered, Explicit, Accessible, Risk-forward.
Establish clear ownership inside the process. Product (or sometimes marketing) owns member comprehension. Legal owns technical accuracy. They are not the same thing.
For insurance guides, work with the insurer on source language early, rather than trying to translate archaic policy wording at the end.
Welcome letters are high-risk for member confusion, especially with regards to default insurance cover. Risk-forward language around cover start dates is essential, not optional.
Accessibility overlays for websites are cheap, available, and underused - worth investigating for your own member-facing content.
AI can help generate plain language drafts but requires human review for legal accuracy.
The consumer testing requirement under the Life Insurance Code applies to retail, not group insurance. That gap matters and is worth raising.
Thanks to Mia Lander for a session that gave our group a genuinely useful new lens on familiar work. If you would like to join the PDS Managers Roundtable invite list, please get in touch.