CPD Flexibility Shouldn't Be Mistaken For Lower Standards

When the FCA removed the mandatory 15-hour CPD requirement, some firms may have seen it as an opportunity to do less. On the surface, that reaction is understandable. Fewer prescriptive rules can feel like lighter regulation, and with budgets under pressure and teams stretched, scaling back on training might look like an easy saving.

More than six months after the change, which applied to certain insurance distribution roles, firms are increasingly shifting their focus from recording learning hours to evidencing competence in practice.

The change, introduced to give firms greater flexibility in designing learning and development programmes, forms part of a broader move towards outcomes-based regulation. While businesses are no longer required to track a specific number of CPD hours for affected employees, responsibility for ensuring staff remain competent has not changed.

The change also does not affect the CPD requirements set by professional bodies. Chartered Insurance Institute (CII) members holding professional designations, for example, are still required to complete 35 hours of CPD each year to maintain their status.

Many firms have kept the 15-hour benchmark, but the focus is increasingly centred on how organisations evidence competence in practice. While the FCA has always expected firms to ensure employees are capable of performing their roles effectively and delivering good customer outcomes, the removal of prescriptive CPD requirements has prompted many firms to review how they assess, support and evidence competence.

An outcomes-focused approach

At Zing365, we see the change as part of a broader move towards outcomes-focused regulation, where firms are expected to demonstrate capability, judgement and customer-focused decision-making. It's also an opportunity for firms to rethink how they approach professional development.

There's a misconception in some parts of the market that the removal of the 15-hour requirement means CPD has become less important. In reality, the opposite is true.

The FCA still expects people to be competent. What's changed is how firms show that competence. Firms have more freedom to decide what's right for their people, but they also need to be able to explain those decisions.

Consumer Duty, SM&CR and wider Training & Competence requirements haven't gone away. In fact, our experience shows that firms are increasingly focused on proving competency rather than simply recording attendance, but many still struggle to measure the impact of training in a meaningful way. Firms should view the change as an opportunity to focus on the quality and relevance of learning rather than simply hitting a numerical target.

It's also important to remember that professional standards remain in place. Many CII-qualified professionals are still required to complete 35 hours of CPD every year, so this isn't about doing less learning. It's about ensuring learning is targeted, relevant and demonstrably effective.

Capability, not activity

For firms adapting to the new requirements, the shift places greater emphasis on capability rather than activity. Completing a set number of training hours has never automatically made someone competent. Someone can attend training and still make poor decisions, while another may undertake less learning but consistently demonstrate strong judgement and customer-focused behaviours.

Firms also need clear evidence that learning is making a difference. That could be assessments, supervision records, quality checks or feedback from managers. The question for firms should be whether they can clearly explain how learning links to role requirements, conduct risk and customer outcomes.

The FCA wants to see why a firm has taken a particular approach and how it knows people remain competent. A spreadsheet showing training hours alone is unlikely to tell that story.

While many firms have retained the familiar 15-hour benchmark, the discussion has moved on. At its best, professional development isn't about ticking a box. It helps people make better decisions, builds confidence and supports better outcomes for customers.

As firms settle into the FCA's revised approach, now is a good time to review how competence is assessed, supported and recorded, and whether existing learning programmes are genuinely helping people develop in their roles.

Our view on CPD flexibility has been covered by Insurance Edge and InsurTech Eye.  

Showing how you know

Zing365 helps insurance firms assess competence across their teams, target learning where it's needed and report on how each person is progressing, so you can explain your approach and show the evidence behind it. Talk to us about moving from recording hours to evidencing competence.