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Terms and policies with no plain-language summary
A subscription's terms sit above its Start button as one paragraph of legal phrasing, so the cancel-by deadline is there only for people who can read it.
<p>By selecting Start subscription, you authorise us…</p> The problem
People who find long, formal sentences hard to read can't tell when they have to cancel by before they sign up
A coffee roaster sells its beans by subscription. The last step of the sign-up shows the terms above the Start subscription button, as the shop's lawyer wrote them: one paragraph of three sentences. They say what the shop charges, when a delivery can still be skipped, paused or cancelled, that a delivery past that point is not refunded, and how much notice comes before a price change.
Someone signing up wants to know one thing before they press the button: how late they can skip a delivery when they go away. The answer is in the middle of the second sentence: "no later than 23:59 on the day preceding the scheduled dispatch date, failing which the delivery shall be deemed confirmed". To find it, they have to read 53 words of formal phrasing and work out what "the day preceding the scheduled dispatch date" means for next week. Nothing on the page says it more simply. Someone who gives up presses the button without the answer, and learns the rule when a delivery they meant to skip is charged and can't be refunded.
Success Criterion 3.1.5, Reading Level, is Level AAA. When text needs reading ability more advanced than the lower secondary education level, about nine years of school, it asks for supplemental content or a version that doesn't. Proper names and titles are left out of the judgement. The terms above are well past that level: their sentences run to 54, 53 and 24 words, built on the passive voice, long formal words where short ones would do ("commencing", "preceding", "corresponding") and phrases such as "failing which" and "save to the extent required by". W3C's technique G153 gives 25 words as the usual length of a sentence for secondary education in English, and asks for one topic to a paragraph, plain sentence forms and the active voice.
Nothing on the page offers anything simpler. The criterion doesn't ask the lawyer to rewrite the terms: a summary in plain words beside them (technique G86), an illustration of what they describe (G103), a spoken version (G79) or a sign language version (G160) each counts. Here there is none of these, so the only way to the deadline is through the legal text.
The terms are at the step where people commit money, and the deadline in them decides whether a missed skip costs them a delivery. The people this criterion is for can't read terms like these even when they try, so they are the ones who can't check what they are agreeing to.
3 of 10 groups affected
- No vision (affected)
- Low vision (not affected)
- Colour vision (not affected)
- No hearing (affected)
- Hard of hearing (not affected)
- No speech (not affected)
- Motor (not affected)
- Reach, strength (not affected)
- Cognitive (affected)
- Seizures (not affected)
- Limited language, cognitive and learning abilities People with dyslexia, an intellectual disability, aphasia or a learning disability, and people reading in a second language, lose the thread of a 53-word sentence before it ends. The one fact they need, the time to skip a delivery by, sits in the middle of that sentence, in legal phrasing such as "deemed confirmed".
- Without hearing For some Deaf people a sign language is their first language and written English a second one, and a sign language version can be easier for them to understand than the passive, formal phrasing of legal text.
- Without vision A screen reader reads the paragraph as one long stream. To hear the deadline again, the listener has to go back into a 53-word sentence and find it in the middle, holding the rest of the sentence in mind.
The markup is correct, so no automated check reports anything: axe and the other rule sets used in audits have no rule for 3.1.5, and EaseWeb's audit has no check for it. A readability formula such as Flesch–Kincaid scores a text on its sentence and word lengths, and puts this paragraph far beyond nine years of school. But a score can't say whether the page offers a summary, and it can't tell a summary that reads easily but leaves out the refund rule from one that is complete. Plain language specialists warn against writing to a formula: shorter sentences of the same words lower the score without making the text clearer. A summary drafted by an AI assistant needs the same check, line by line against the terms: a summary that drops "the day before it ships" changes what people think they are agreeing to. Whether the plain version is right, and whether readers can use it, takes a person who knows the terms and a few people who will read them.
Try it
Find the last moment you can skip a delivery, before you start the subscription
The answer is in the terms. Under the page, each bar is one sentence on show, measured in words; the dashed line is 25 words, the length W3C gives for a sentence at secondary school. Then apply each fix and look again.
Broken Can you fix this?
Subscription terms
By selecting Start subscription, you authorise us to charge your chosen payment method the subscription price then in effect, together with any applicable delivery charges, at the frequency you have selected, commencing on the date of your first order and continuing until such time as your subscription is cancelled in accordance with these terms. Any request to skip, pause or modify a scheduled delivery, or to cancel your subscription, must be received no later than 23:59 on the day preceding the scheduled dispatch date, failing which the delivery shall be deemed confirmed and the corresponding charge shall be non-refundable save to the extent required by applicable law. We reserve the right to revise subscription pricing upon not less than 30 days' prior notice to the email address associated with your account.
Length of each sentence on show
Subscription terms
- 54 words
- 53 words
- 24 words
Dashed line: 25 words
The fix
Give the terms in plain words, before the button
<section class="terms"> <h2>Subscription terms</h2> <p> By selecting Start subscription, you authorise us to charge your chosen payment method the subscription price then in effect, together with any applicable delivery charges, at the frequency you have selected, commencing on the date of your first order and continuing until such time as your subscription is cancelled in accordance with these terms. Any request to skip, pause or modify a scheduled delivery, or to cancel your subscription, must be received no later than 23:59 on the day preceding the scheduled dispatch date, failing which the delivery shall be deemed confirmed and the corresponding charge shall be non-refundable save to the extent required by applicable law. We reserve the right to revise subscription pricing upon not less than 30 days' prior notice to the email address associated with your account. </p> <button type="submit">Start subscription</button></section>What is wrong3 points
- The three sentences run to 54, 53 and 24 words, in the passive voice and legal phrasing.
- The deadline to skip, pause or cancel a delivery is in the middle of the second sentence.
- Nothing on the page says the same thing in plain words.
A plain summary above the terms
<section class="terms"> <h2>Subscription terms</h2> <h3>In short</h3> <ul> <li>You pay $24 every 2 weeks, plus delivery, until you cancel.</li> <li>To skip, pause, change or cancel a delivery, do it by 23:59 the day before it ships.</li> <li>After that, the delivery goes out and we don't refund it, unless the law says we must.</li> <li>We'll email you at least 30 days before the price changes.</li> </ul> <h3>Full terms</h3> <p> By selecting Start subscription, you authorise us to charge your chosen payment method the subscription price then in effect, together with any applicable delivery charges, at the frequency you have selected, commencing on the date of your first order and continuing until such time as your subscription is cancelled in accordance with these terms. Any request to skip, pause or modify a scheduled delivery, or to cancel your subscription, must be received no later than 23:59 on the day preceding the scheduled dispatch date, failing which the delivery shall be deemed confirmed and the corresponding charge shall be non-refundable save to the extent required by applicable law. We reserve the right to revise subscription pricing upon not less than 30 days' prior notice to the email address associated with your account. </p> <button type="submit">Start subscription</button></section>How it is fixed4 steps
- Add a summary under the terms' heading, headed "In short", as technique G86 describes. People read it first, and it sits between the terms' heading and the button.
- Write it as a list, one point to an item, each a short sentence in common words with the reader as "you": the price, the deadline, the refund rule and the notice of a price change.
- Give each point the values of the order, such as $24 every 2 weeks, so nobody has to work them out from "the frequency you have selected".
- Keep the legal paragraph under its own heading, "Full terms", word for word.
This fixes the Before and passes 3.1.5: the summary needs no more than lower secondary reading ability, and its sentences run to between 11 and 17 words. The full terms are still hard to read, which the criterion allows, since the summary is offered beside them. It holds only while the summary keeps up with the terms: when the terms change, the summary changes in the same edit.
Both pass, and both keep every charge, deadline and refund rule in front of the button. The summary is the smaller change: it leaves the legal text exactly as written, which is often the condition a legal team sets, but it adds a second text that has to change whenever the terms do, and a reader who wants the binding words still meets the hard ones. The rewrite leaves one text that everyone can read and nothing to drift, but it needs the legal team's time and agreement. Choose the rewrite when the people who own the terms will sign off plain wording; choose the summary when the legal text has to stay as it is.
What the summary has to say. A summary leaves things out by design, but not what costs money or ends a right. Before it is published, list each charge, deadline, renewal and refund rule in the full terms, and check that each is in the summary with the same values. Creative Commons' licence pages are a well-known model: a short summary first, a line saying that it highlights only some of the terms and is not the licence, and a link to the full legal code.
Where it goes. Put the summary at the step where people decide, before the button, not on a separate policy page that the step links to. Its heading should say what it is, such as "In short", so people who jump by headings find it. Folding the full terms into a details element under the summary keeps the step short; they are still on the page for anyone who opens them. Pinterest's terms take another approach: a plain line under each section, headed "More simply put".
Keep the two in step. Store the summary beside the terms, wherever the terms are edited, and make the review of a terms change include the summary. A summary that still says "30 days" after the terms say 14 is worse than none.
Measuring the level. The criterion's level is lower secondary education, about nine years of school. In English, readability formulas such as Flesch–Kincaid turn sentence and word length into a school grade; they are a quick first check, not a verdict, and a text that passes one can still be unclear. WCAG names no formula, in any language. For Japanese, Japan's government guidance on writing for the public, 公用文作成の考え方 (2022), advises one point to a sentence, a list for three or more items, the conclusion first, and a second look at any sentence that reaches 50 to 60 characters. The surest check is the one plain language practice recommends: ask a few people from your audience to find the answer they need.
Other ways to meet it. An illustration of what the text describes, such as a timeline of the billing cycle with the skip deadline marked on it, is supplemental content too (G103), as is a recording or a "Listen" button (G79), or a sign language video (G160). Each must say the same thing as the terms. A timeline also needs its text alternative for 1.1.1, and a spoken version helps people who can't decode the words, not people who can't follow the sentence.
In Japan, the law asks for something close. The Consumer Affairs Agency's guideline on what an online shop shows at the final confirmation step asks for the conditions for cancelling to be shown on that screen, as far as possible, in a way that is easy to understand, and allows the details to be on a linked page when showing them all would make the screen hard to follow.
Design ideas
A plain summary can take more than one shape
Three more ways to put the same terms in plain words beside the button, and two looks that leave them as hard to read as before. Tab through them, and open what opens.
In the design file
- Write the real summary into the design, not placeholder text, since its words and their length are part of the layout.
- Put the summary before the button, where people decide, and the full terms after it.
- Give each point a line of its own, as one short sentence that starts with what people pay or have to do.
- Show every deadline as a day and a time, and keep each charge and refund rule in the summary.
Passes
- Today First bag, $24
- Day before it ships, 23:59 Last moment to skip or cancel
- Ships Next bag, $24
Then every 2 weeks, until you cancel.
Timeline of the billing cycle The cycle drawn as three stops on a line, each in words, with the deadline as its own marked stop rather than a clause in a sentence. It is drawn in text, so it zooms and translates with the page.In plain words: skip or cancel by 23:59 the day before a bag ships.
Any request to skip, pause or modify a scheduled delivery, or to cancel your subscription, must be received no later than 23:59 on the day preceding the scheduled dispatch date, failing which the delivery shall be deemed confirmed.
A plain line with each clause Each clause of the legal text keeps its place, with a plain line on a cream band before it in the site’s own voice, as Pinterest’s terms give each section a “More simply put” line. People read the plain line first.- $24 every 2 weeks, plus delivery, until you cancel.
- Skip or cancel by 23:59 the day before it ships.
- After that, the bag ships as planned.
Read the full terms
Any request to skip, pause or modify a scheduled delivery, or to cancel your subscription, must be received no later than 23:59 on the day preceding the scheduled dispatch date, failing which the delivery shall be deemed confirmed.
Summary open, full terms folded Three points stay in view and the legal paragraph folds away under them, so the step stays short. The full terms are still on the page for anyone who opens them.
Fails
Any request to skip, pause or modify a scheduled delivery, or to cancel your subscription, must be received no later than 23:59 on the day preceding the scheduled dispatch date, failing which the delivery shall be deemed confirmed.
Fine print under the buttonWCAG 3.1.5 The clean look many checkouts ship: one bold button with the terms set small beneath it. Every word is there, still in legal phrasing, and nothing says it more simply.Key points
- Recurring charges apply at the selected frequency until termination.
- Modifications must be effected prior to the cut-off.
- Dispatched orders are non-refundable save as required by law.
Key points in the terms’ own wordsWCAG 3.1.5 It looks like a plain summary, but it is the terms cut shorter: the same kind of formal words, and the deadline has become “the cut-off”, with no day or time at all.
Verify the fix
5 checks, no mouse.
Test with: Readability check
Record the OS, browser and assistive-technology versions, the build, the date, and the actual result of each step. Repeat whenever the terms change.
Limits
This is a starting pattern, not a guarantee. 3.1.5 is Level AAA, above the AA level most policies ask for, but terms people agree to are where unreadable text costs them most. The criterion doesn't ask for every text to be simple: a hard text with a plain version beside it passes. The example is one block of terms; returns policies, privacy notices and setup instructions take the same fixes. Single words that need explaining are a different failure: see jargon and unusual words with no definition. So are abbreviations: see abbreviations and acronyms that are never spelled out. Readability formulas and reading level differ between languages, so measure each language a site ships in.
This is a recreated teaching example, not a finding about a named client. The code is a starting pattern: test it in your own product. No completed assistive-technology test is claimed here.
References
- WCAG Understanding: reading-level (opens in a new tab)
- WCAG Technique G86 (opens in a new tab)
- WCAG Technique G153 (opens in a new tab)
- WCAG Technique G103 (opens in a new tab)
- WCAG Technique G79 (opens in a new tab)
- WCAG Technique G160 (opens in a new tab)
- our-languages.canada.ca: readability-formulas-eng (opens in a new tab)
- bunka.go.jp: 93731901_01.pdf (opens in a new tab)
- no-trouble.caa.go.jp: 20241119la02_09.pdf (opens in a new tab)
- creativecommons.org: deed.en (opens in a new tab)
- policy.pinterest.com: terms-of-service (opens in a new tab)
EaseWeb service
Fixed it? Keep it from coming back.
I turn guides like this one into rules your coding agents follow and checks your CI runs. Then I retest by hand with a keyboard and screen readers, periodically.