Using a 2Mb embedded Flash cell array as a demonstrator, we reported previously that a 3V reduction in programming voltage was possible by replacing the ONO interpoly dielectric (IPD) with an IPD comprising the high-k material, Al 2 O 3 [1]. Adding a thin protective top-oxide to the high-k IPD was later shown to significantly improve reliability [2]. In this paper, we show that for integration schemes more suited to the material properties of Al 2 O 3 , reliably functioning 2Mb demonstrators with a high-k IPD but without top-oxide protection are also feasible.