Bridging the communication gap

Read time: 4-5 mins

Listening to the industry chatter these days, there is a constant tension. With AI becoming a key audience, a common ‘buffer’ before human access or perception, issuers are understandably keen to get a handle on how publications are being summarised by large language models (LLMs), a type of AI, and generative engine optimisation (GEO), optimising content for AI search engines, to ensure they have control of the narrative. The risk that messages will be misinterpreted, diluted or hallucinated by AI is understandably worrying, and leads to unclear messaging.

On the other hand, we have another audience of regulators, investors and issuers who have expressed a strong preference for PDF and printed documentation – these documents have a concrete quality, they are seen as trusted, fixed at a point in time and subject to board scrutiny.

From a regulatory perspective, legislation is clearly moving towards supporting a digital-first approach. The Disclosure Guidance and Transparency Rules now posit the ESEF or UKSEF xHTML submission as the official annual report for Main Market listed companies – the format being PDF doesn’t actually ‘count’ for anything.

The advent of deemed consent processes means printed copies have dropped massively in the last decade as companies also think more about the environmental impact of printing reports. For some companies domiciled outside of the UK, they aren’t even required to produce printed copies at all.

Even Companies House is shaking off its reputation as a dusty old library and modernising, with many of our clients now successfully digitally submitting their UKSEF tagged versions to Companies House via their new portal instead of doubling up on printed or mono versions.

We also have new accessibility rules from Europe supportive of tagged and structured marketing communications. With clear hierarchies, labelling and alt text, a screen reader can interpret what it’s reading and navigate around the document in the right order.

We need to remember that a PDF often behaves a bit like an image – the words and image don’t always make sense to a non-human reader. Imagine an optical character recognition (OCR) machine crawling over a document – it can make out the text via contrast and shapes but misses context clues. With tags, schema mark-up and alt text, screen readers can make sense of what they’re reading, what the text is describing and what order it flows in – an elevated structure for someone visually impaired using a screen reader. Those same accessibility elements also elevate understanding for AI readers.

(The uptake and appetite for universally accessible PDFs (PDF/UAs) in the UK has been slow to say the least, with only around 5% of the FTSE 100 offering an accessible PDF in 2025 – but we expect this figure to rise in the coming years when people realise elevating for screen readers also elevates comprehension for an AI audience, as well as the commencement of lawsuits in Europe as the EAA beds in.)

So, why are we all designing for PDF first? Why does the PDF remain king?

In our recent round of FTSE 100 research, we found that all the FTSE 100 companies produced a PDF report. However, there are clear signs that leaders and innovators in the space are using a more truly digital-first approach.

What’s the issue?

PDFs aren’t super accessible by machine readers and they are not very interactive. They also require messy (or at least, imperfect) conversion to get to the xHTML format that is required under the Disclosure Guidance and Transparency Rules for formal submission of the annual report just four months after year end for Main Market listed companies.

They do still have a place however; they are seen as a trustable, ‘point-in-time’ source of truth, subject to scrutiny by auditors and signed off by the board. But catering to our new audience of AI and digital, mobile-first, skim human readers requires a refreshed approach, rather than treating this audience as an afterthought.

As we move towards more tagging, more accountability, more data and more accessibility, the format of the report is becoming as important as the substance.

What next?

As an independent agency, we’re agnostic on ways of working, and we’re free to pick and choose which providers and platforms we work with. Through our clients and industry partners we can cater to a range of appetites and budgets. Having offered microsites and websites for years, we’re currently positioning ourselves to offer digital-first or HTML-first reporting, avoiding the need to design for print first and then reformat this content for the web. This approach has the potential to simplify version control, reduce time pressure at sign off, increase digital and AI accessibility, as well as act as a single-source platform for data collection and self-editing.

If you’d like to find out more about trends in FTSE 100 reporting, insights in current and future legislation, and practical steps to shift to digital-first reporting alongside ARKK and Tangelo, please sign up to our webinar on Monday 11 May at 10am BST. You’ll receive a calendar invite and have opportunities to ask questions in advance here.