Statement from the CII on the FCA's CPD consultation

The FCA has recently announced that it will consult on removing the regulatory requirement for people working in general insurance to complete 15 hours of ongoing training every year. It may look at first sight as though the regulator is having second thoughts about the value of education and training.

However, the FCA’s requirement for individuals working in insurance to ‘possess appropriate knowledge and ability in order to complete their tasks and perform their duties adequately’ has not been called into question. As such, while the idea of scrapping the 15-hour requirement may reduce the regulatory burden superficially, the high-level standard (which can be applied with hindsight when consumer harm is detected) is still very demanding – the regulator’s expectations of insurance professionals will remain the same.

Education and training are vital aspect of these standards because they:

• build up technical competences that improve the delivery of goods and services;
• build a range of behaviours and skills that help professionals to better understand consumer needs and to behave with integrity;
• help professionals to adapt positively to change by continuously updating skills.

Continuous professional development is a crucial element of professionalism because it allows individuals to adapt to a constantly changing technological, economic and social environment. Whilst we all learn by experience, professional development gives structure to the learning process by:

• setting objectives;
• identifying relevant learning opportunities; and
• adding the discipline of reviewing what has been learnt and identifying remaining gaps.

As a professional body, we have always had the ability to set our own standards for our members. Whilst they have often aligned with those of the regulator, we have typically set standards which go beyond regulatory minima, consistent with our Royal Charter purpose to maintain and build public trust in the profession. Our standards for professional competence come through the Professional Map, our qualification syllabuses, and our 35-hour CPD requirement. This requirement has been consistent for many years.  In contrast, the FCA’s regulations have varied between requiring no CPD (Insurance Mediation Directive, which was introduced in 2005) to 15 hours (when the Insurance Distribution Directive was introduced in 2018).

We responded to the FCA’s original call for input. Consistent with the above, we noted in our response that there will always be a balance to be struck between rules and regulations, and the responsibility on professionals to do the right thing. By supporting our members to do just that, we give the FCA the freedom to focus on creating and enforcing detailed rules where competitive pressures make other voluntary arrangements difficult to sustain. 

We have no plans to alter our CPD expectations for our members.