I recently had a great conversation with Duff Johnson from the PDF Association. Duff has spent his career advocating for PDF, and for good reason. PDF has been one of the most important and enduring standards in enterprise communications.

I’ve personally spent more than 30 years working with PDF and Adobe Acrobat, going back to the early days when simply being able to preserve layout digitally was transformational.

So this conversation with Alan Berger is not about whether PDF is good or bad. It’s about asking a different question.

Is the document of record inseparable from the page, or are there now compliant alternatives that better align with how customers and systems interact today?

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For decades, regulated customer communications have followed a familiar pattern.

A document is created, delivered and archived.A checkmark for compliance.

That model made sense in a paper-first world where proof of delivery was the primary objective. Proof that something was sent. Proof that it was printed. Proof that it could be retrieved years later if needed.

But the world around those communications is changing.

In my recent Above the Treeline podcast conversation with Alan Berger, CEO of InfoSlips North America, we kept returning to the same realization. The industry is not being held back by technology. It is being held back by a mindset that still treats communications as the end of the process rather than part of an ongoing relationship. A conversation.

This is not a debate about whether PDFs are good or bad. PDFs remain an important and reliable workhorse across regulated industries. The issue is more subtle and more consequential.

The problem emerges when page-based, document-centric thinking becomes the ceiling for digital progress.

When the page became the experience

Most regulated communications today are still shaped by their print origins.

The same file that once drove a printer is now delivered through a portal or an email notification. From an operational perspective, very little has changed. Only the transport mechanism is different.

From a compliance standpoint, the requirement may be satisfied, but from a customer standpoint, the experience often feels disconnected from everything else.

Customers engage with organizations through mobile apps, websites, alerts, and messaging channels that are responsive and contextual. When a statement, policy notice, or regulatory disclosure arrives as a static artifact, the contrast is immediate.

In my conversation with Alan, he described how regulated communications are often viewed as a sunk cost. Something the business has to do, not something it can learn from, improve, or design around customer understanding.

As a result, these communications frequently sit outside digital transformation programs, outside customer experience strategies, and outside AI roadmaps.

What regulation actually requires

One of the most persistent myths in this industry is that regulation mandates a specific format.

In reality, most regulations focus on outcomes, not file types. They emphasize immutability, audit readiness, authentication, retention, and accessibility. They do not require information to be delivered as a page-based document, just that they are “written communications” or “in writing.” This distinction matters.

From a UK perspective, the direction of travel is becoming clearer through the FCA’s Consumer Duty framework and the more recent PS25/13 policy statement. Together, they indicate a shift away from fire-and-forget communications toward proof and performance.

The regulator is no longer focused solely on whether information was sent. Increasingly, firms are expected to demonstrate that communications support customer understanding and appropriate outcomes.

Electronic delivery becomes the default not because digital is convenient, but because digital enables evidence. Evidence enables testing. Testing enables improvement.

Digital delivery is not digital experience

Many organizations believe they have modernized because they reduced print volumes or moved customers to online portals.

But placing a PDF behind a login screen does not create a digital experience. It simply relocates a legacy artifact.

For customers, especially on mobile devices, long documents can feel more like images than information. They are difficult to navigate, difficult to interpret, and disconnected from the moment the customer is trying to resolve.

Most communications were built to optimize production and distribution, not comprehension and interaction.

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Strategic distance and why leaders are pulling ahead

This issue becomes even clearer when viewed alongside broader global banking transformation.

In its research on how retail banks build strategic distance, McKinsey & Co describes how leading institutions are separating themselves from competitors through digital capabilities that reshape customer experience, not just operational efficiency.

The consistent message is that differentiation no longer comes from products alone. It comes from how effectively organizations design and connect customer journeys.

Digital leaders do not modernize one part of the experience while leaving others frozen in time.

Rethinking the document of record

The document of record still matters. Immutability still matters. Auditability still matters.

What changes is how the customer interacts with that information.

Instead of freezing experience at the moment of composition, communications can be structured in ways that allow them to adapt across devices, support accessibility by default, and present information in context.

The record remains intact, but the experience becomes dynamic.

This distinction becomes even more important as AI and agent-driven experiences begin to shape how people interact with information. Agents do not read pages. They work with structure, context, and meaning.

From documents to understanding

At its core, this is not a file format discussion. It is a purpose discussion.

Is the goal simply to deliver information, or is it to ensure understanding?

When communications are designed around understanding, they can reduce confusion, lower call center demand, improve satisfaction, and strengthen trust. When they are designed solely around output, they quietly introduce friction at exactly the wrong moment.

The traditional model of produce, send, archive is not wrong. It is just no longer enough.

Andy’s Thoughts

The future of regulated communications will not be defined by whether something is paper or digital, PDF or not PDF. It will be defined by whether the communication helps someone understand what matters to them at the moment they need it.

Compliance will always matter. Records will always matter.

But selecting a channel and checking a box is no longer the finish line.

The organizations that pull ahead will be the ones willing to look beyond the page.

That shift is already underway.

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