FCA Removes Mandatory 15-Hour CPD Requirement: What This Means for Professional Standards

The Financial Conduct Authority has today confirmed significant changes to continuing professional development requirements for the insurance and funeral plan sectors, removing the mandatory 15-hour annual CPD minimum that has been in place since 2018. Published in Policy Statement PS25/21, these changes mark a fundamental shift in how professional competence is regulated in these industries.

What Has Changed?

Under the new rules, firms in insurance markets will no longer be required to ensure their employees complete at least 15 hours of CPD every year. Instead, organisations will have greater flexibility to determine appropriate training requirements based on specific roles and business needs.

The FCA has been clear that this is not a relaxation of competence standards. Graeme Reynolds, Director of Competition and Interim Director of Insurance at the FCA, stated: "We're simplifying and removing rules for insurers and brokers, reducing regulatory costs and helping them focus on delivering better outcomes."

The regulator maintains that firms remain responsible for ensuring employees possess appropriate knowledge and competence to perform their roles adequately. The fundamental requirement for competence has not changed—only the prescriptive measurement of it.

The Rationale Behind the Change

The FCA's decision follows consultation feedback that revealed the 15-hour minimum was, in many cases, either insufficient for complex roles or unnecessarily burdensome for simpler functions. Many roles in the insurance sector already require significantly more than 15 hours of training to maintain appropriate competence levels.

The regulator argued that investment in training and development improves standards that build trust among consumers and corporate buyers, thereby supporting growth. By removing the fixed requirement, firms can now tailor professional development programmes to the actual needs of their workforce and the demands of their business.

Industry Response and Professional Standards

The response from professional bodies has been mixed. The Chartered Insurance Institute (CII), which maintains its own 35-hour CPD requirement for members—more than double the previous FCA minimum—has indicated it will continue to uphold its higher standards regardless of the regulatory change.

This highlights an important distinction between regulatory minimums and professional excellence. While the FCA sets baseline requirements for market conduct, professional bodies and accreditation organisations establish benchmarks for best practice and professional standing.

Implications for CPD Quality and Verification

This regulatory shift underscores the increasing importance of CPD quality over quantity. With no prescribed hourly requirement, the focus shifts to demonstrable competence and the effectiveness of professional development activities.

For organisations providing CPD accreditation services, this change emphasises the critical role of quality assurance in the professional development landscape. The question is no longer simply "how many hours?" but rather "how effective is the learning?" and "can competence be demonstrated?"

This is where independent certification and quality standards become increasingly valuable. When regulatory minimums are removed, market-led quality assurance mechanisms become the differentiator between genuine professional development and box-ticking exercises.

What This Means for Professionals

For individual professionals, the removal of the 15-hour requirement doesn't diminish the importance of continuous learning. In fact, it may increase personal accountability for maintaining and demonstrating competence.

Professionals should consider:

• How their employer's training programmes align with their role requirements and career development
• Whether additional professional development is needed beyond employer-provided training
• The value of professional body memberships and their associated CPD requirements
• How to evidence competence in the absence of a standardised hour-count metric

The Broader Context: A Move Towards Outcomes-Based Regulation

The FCA's decision reflects a broader regulatory trend towards outcomes-based frameworks rather than prescriptive rules. This approach, exemplified by the Consumer Duty introduced in recent years, focuses on the end result—good customer outcomes and maintained competence—rather than prescribing exactly how firms should achieve them.

This shift places greater responsibility on organisations to design and implement effective training and development strategies that genuinely enhance capability, rather than simply meeting a numerical target.

Looking Ahead

The FCA has indicated it will monitor the situation closely and will be prepared to review training and development practices to ensure the overarching competence requirements are being met. This suggests that while the prescriptive requirement has been removed, regulatory scrutiny of competence and capability will continue.

For the wider CPD industry, this change may serve as a catalyst for innovation in how professional development is delivered, measured, and verified. Quality assurance, independent accreditation, and demonstrable learning outcomes are likely to become even more important as differentiators in the market.

Further Changes on the Horizon

Alongside the CPD changes, the FCA has also removed the requirement for mandatory annual product reviews, instead requiring firms to schedule reviews based on risk and potential for customer harm. The regulator has also announced plans for further changes affecting insurance firms in 2026, including reviewing the international application of its rules and the Consumer Duty.

The CPD Register is an independent certification body that evaluates and certifies CPD accreditation organisations, providing quality assurance and transparency in the professional development sector. For more information about certified CPD providers and quality standards, visit www.thecpdregister.com.

Source: FCA Policy Statement PS25/21 - "Simplifying the insurance rules" (Published 9 December 2025) https://www.fca.org.uk/publications/policy-statements/ps25-21-simplifying-insurance-rules