How do you ensure that agreements, general terms and conditions and other legal documents are accessible to all your clients? By writing it at an easier, accessible language level. It sounds simple, but it is not. Consultant Daniëlle Geelen took up this challenge for a Projective Group client. The result: a licence application with AFM was approved and they are one step closer to complying with the accessibility directive for financial institutions.
A new challenge awaits financial institutions: the Accessibility Directive, which comes into force on 28 June 2025. Among other things, this directive requires information on products and services, including financial products such as mortgages, current accounts and investment services, to be comprehensible to a wide audience, including the digitally literate and illiterate. This means that financial institutions must write their documents in accessible language, often at B1 or B2 level.
A client of ours wanted to apply for a licence from the AFM. The client, active in several countries, needed to submit agreements and terms and conditions shown to Dutch customers. The AFM stresses the importance of understandable contracts and conditions, preferably written at language level B1, although in the financial world B2 is also sufficient. Having worked with this client before, there was already a good basis for this project. Our consultants combined a legal view and knowledge with the right language level, resulting in a comprehensible document that could be submitted to the AFM.
“The directive focuses on more than just the language level. Conditions and information provision in any way should be accessible, as should the website.”
The result was positive. The AFM was satisfied with our approach. This case confirms that rewriting general terms and conditions at a more accessible language level is indeed possible. You not only offer clarity to the customer but also meet all legal requirements.
In Europe, we have six language levels: from A1 to C2. This scale indicates the level at which a person understands, speaks and writes a language. Language levels A1 and A2 apply to basic users. B1 is the language level that low-literate people understand, but highly educated people also find pleasant to read, if done well. 18% of Dutch people are low literate, so the need for language levels B1 or B2 is high.
Rewriting legal documents to a more accessibel language level, while keeping them legally correct, requires a change in thinking. Therein lies directly a fear of financial institutions: how do we keep documents legally correct at a lower language level? It feels safe and comfortable to seal documents completely with legal provisions. However, in practice, many of these provisions are rarely needed. It is therefore possible and desirable to formulate in understandable language what is expected from a customer and what the customer can expect from the service provider.
“First, it requires a change in mindset to embrace a lower level of language. People fear too easy content, but if documents are correctly rewritten, then everyone benefits.”
Projective Group’s consultants know the market and the needs of regulators like no other. Because we have not only linguistic, but above all legal expertise, we are able to retain nuances while rewriting documents into understandable language. This project shows that we are able to write legal documents such as general terms and conditions at a level that is both customer-friendly and legally correct. Besides rewriting legal documents understandably, our consultants are also ready to perform a check for consistency and compliance with the latest legal requirements. We have proven experience and a deep understanding of both the legal and practical aspects of this challenge.
