Since 9 December 2025 insurance distribution staff no longer have to complete a fixed 15 hours of continuing professional development each year. PS25/21 removed the prescribed minimum. What remains is the duty to make sure every relevant employee has the knowledge and ability to do their job (SYSC 28.2.1R and the competent employees rule), backed by guidance that still expects continuing training and by record keeping.
In practice that asks more of firms, not less. A fixed number of hours could be evidenced with a log. A role-based standard has to be designed, justified and shown to work. The FCA said the change is not a relaxation of competence expectations, and the Chartered Insurance Institute opposed it.
Before and after
| Area | Before 9 December 2025 | Now |
|---|---|---|
| Yearly CPD | At least 15 hours for relevant staff | No prescribed minimum |
| Competence | Required | Still required (SYSC 28.2.1R; SYSC 3.1.6R or 5.1.1R) |
| Continuing training | Required, measured in hours | Still expected (SYSC 28.2.1AG and 28.2.2AG), judged by quality and fit to the role |
| Records | Required | Still required (SYSC 3.2.20R or 9.1.1R) |
| Who sets the standard | The rule | The firm, with a recorded rationale |
A role-based training plan
| Role | Core knowledge | Typical evidence |
|---|---|---|
| Advisers and account handlers | Products sold, demands and needs, suitability, disclosure, Consumer Duty outcomes, vulnerability | File review results, assessed training, product updates |
| Claims handlers | Claims rules, fair settlement, vulnerability, complaints | Claims file reviews, case discussions |
| Underwriters and product staff at MGAs | Product governance, fair value, delegated authority terms | Product review participation, training records |
| Senior managers and certified staff | Responsibilities, conduct rules, regulatory change | Fitness and propriety assessment, board training |
| Compliance and risk | Rule changes, monitoring methods | Professional qualifications, regulatory update log |
Set the content and amount of training for each role from its risk: what goes wrong for customers if this person lacks knowledge. Record that reasoning once a year, update it when rules or products change, and test competence through file reviews rather than attendance alone.
What supervisors and auditors will look for
- A written training and competence policy explaining how the firm sets its standard now there is no minimum.
- A plan by role, with the reasoning behind it.
- Evidence that training changed practice, for example improved file review scores.
- Records kept for each employee.
- Links to the yearly fitness and propriety assessment of certified staff under SM&CR (PS26/6 changed several SM&CR processes in 2026).
Setting your own standard in five steps
- List every role that needs competence under SYSC 28. Include advisers, account handlers, claims staff, product and underwriting staff, and the people who supervise them.
- Define what each role must know. Start from the products sold, the customers served and the rules that apply, including the Consumer Duty outcomes where the business is in scope.
- Set the training by risk. Higher-risk roles, such as advised sales to retail customers or claims handling for vulnerable customers, need more frequent and more assessed training than lower-risk roles.
- Test competence, not attendance. Use file reviews, assessed modules and supervisor sign-off to show staff can apply what they learned.
- Review once a year and on change. Record the review, and update the plan when products, rules or outcomes data change.
Common gaps
- The old 15-hour target kept as a habit, with no record of why it is still the right amount.
- Training logs that show attendance but no assessment.
- Product launches with no product-specific training for the staff selling them.
- No link between file review findings and individual training plans.
- Certified staff assessed as fit and proper without evidence of current competence.
How it links to the Consumer Duty
For business in scope, the consumer understanding and consumer support outcomes depend on staff who can explain cover clearly and handle claims and complaints well. Weak competence shows up in outcomes data: complaints about mis-explained cover, high cancellation in the cooling-off period, or declined claims that should have been foreseen at sale. Using that data to direct training is the clearest evidence a firm can give that its own standard works.
Our broker compliance checklist places training alongside the other people checks, and our rule change tracker lists every related change.
Frequently asked questions
No. PS25/21 removed the prescribed 15-hour yearly minimum from 9 December 2025. Firms must still keep staff competent and keep training records.
SYSC 28.2.1R requires relevant employees to have appropriate knowledge and ability, alongside the competent employees rule in SYSC 3.1.6R or SYSC 5.1.1R. Guidance in SYSC 28.2.1AG and 28.2.2AG still expects continuing training, and records must be kept.
There is no fixed number. Each firm should set training by role, based on the risk of customer harm if knowledge is lacking, record its reasoning and test that training works.
No. The FCA said removing the hours minimum is not a relaxation of competence expectations; it shifts the focus to quality and relevance.
A training and competence policy, a role-based plan with its rationale, employee training records and evidence that training improved outcomes, such as file review results.
References
About Regulatory Counsel
Regulatory Counsel provides compliance support for insurance brokers and MGAs: monitoring and file reviews, product governance and fair value, Consumer Duty reporting, client money, training and competence, and regulatory returns. Every enquiry is answered the same business day with a written proposal: contact us.
This article is general information as at 27 October 2026 and is not legal advice.
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