Retail investment advisers must complete at least 35 hours of CPD in every 12-month period, and the FCA’s guidance is that at least 21 of those hours should be structured. The requirement sits in rule TC 2.1.15R of the FCA Handbook. On top of the hours, an accredited body must independently verify each adviser’s qualifications, CPD and annual declaration every year, which in practice means holding a valid Statement of Professional Standing (SPS).
That 35-hour figure is specific to retail investment advice. Mortgage advisers have no fixed hours in the FCA’s rules, and since 9 December 2025 general insurance and pure protection staff no longer have the 15-hour requirement many firms still quote. This guide sets out who needs what, what counts as structured CPD, and the other training duties that apply to advice firms whatever the adviser’s CPD position.
At a glance: Nexis CPD offers £9 CPD-accredited online courses relevant to financial services, including Anti-Money Laundering Awareness and Data Protection and GDPR Awareness, each with a verifiable e-certificate, and any three courses cost £18.
How many CPD hours do financial advisers need?
For retail investment advisers, the rules are in chapter 2 of the FCA’s Training and Competence sourcebook (TC):
- TC 2.1.15R: a retail investment adviser must complete a minimum of 35 hours of appropriate continuing professional development in each 12-month period.
- TC 2.1.16G: the adviser should complete no less than 21 hours of structured CPD activities.
- TC 2.1.26R: the adviser makes a written annual declaration.
- TC 2.1.17R: a firm may suspend the CPD requirement during periods of leave or long-term illness.
Notice the letters after the rule numbers. An “R” is a rule; a “G” is guidance. The 35 hours is a binding rule. The 21 structured hours is guidance, so the precise wording is that advisers should complete it. In practice, accredited bodies expect it, and an adviser who habitually falls short of 21 structured hours will struggle to justify it at verification. Treat 21 as the working minimum.
Pension transfer specialists
Pension transfer specialists have an additional, separate requirement under TC 2.1.23AR: 15 hours of CPD, of which 9 should be structured and 5 external. It is set out as a distinct requirement, so check with your firm and accredited body how the two interact if you hold both roles.
What is a Statement of Professional Standing?
The hours are only half of it. Under TC 2.1.27R, a firm must obtain independent verification from an accredited body of each retail investment adviser’s qualifications, CPD and annual declaration. TC 2.1.28R sets the timing: within 60 days of the date the adviser was assessed as competent, and within 60 days of each anniversary after that.
FCA guidance at TC 2.1.29G says that verification should take the form of a Statement of Professional Standing issued by an accredited body. The FCA’s professional standards page for advisers states that advisers must hold an annual SPS, valid for a maximum of 12 months from the date of verification.
There are currently three FCA accredited bodies that issue SPSs: the Chartered Institute for Securities & Investment (CISI), the Chartered Insurance Institute (CII), and Walbrook Institute London, formerly known as the London Institute of Banking & Finance.
The practical effect is simple even though no single rule says it in one sentence: without a valid SPS, the firm cannot show the independent verification the rules require, and the adviser should not be advising retail clients on investments. Letting an SPS lapse is one of the few administrative failures that stops an adviser working overnight.
The 10% sample check
According to the FCA, accredited bodies carry out a random 10% sample check of CPD. If you are selected, you will be asked to evidence what you recorded. This is where vague records come unstuck: “reading, 10 hours” with nothing behind it is hard to verify; a list of specific articles with dates and a line on what each changed is not.
What counts as structured CPD for the FCA?
FCA guidance gives the examples directly.
Structured CPD (TC 2.1.20G) includes courses, seminars, lectures, conferences, workshops, web-based seminars and e-learning. The FCA describes it as an activity designed to achieve a defined learning outcome.
Unstructured CPD (TC 2.1.21G) includes conducting research relevant to your role, reading industry or other relevant material, and coaching or mentoring sessions.
Two further tests apply to all CPD under TC 2.1.22G. It should be relevant to the adviser’s current role, and it should be measurable and capable of being independently verified by an accredited body. The rules also warn, at TC 2.1.22AR, that an e-learning module of very short duration may not contribute.
Applying the tests
Relevance is where most CPD plans go wrong. A 35-hour year made entirely of product and market updates looks relevant on paper but often leaves gaps in areas the regulator actually examines: vulnerable customers, Consumer Duty outcomes, financial crime, and suitability. The best CPD plans start from the adviser’s weakest file, not from whichever webinars arrived in the inbox.
Measurability rules out a lot of good learning that was not documented. The conversation with a paraplanner that changed how you present risk is real CPD, but only if you wrote down what happened and what changed.
And the length test matters for online learning. A three-minute compliance “micro-module” may be useful but may not count. Log the time you actually spent, and prefer modules with a defined learning outcome and an assessment.
Do mortgage advisers and insurance advisers have CPD hours?
Mortgage advisers
The FCA’s training and competence rules set no fixed number of CPD hours for mortgage advisers. The hour figures in TC 2.1 relate to retail investment advisers and pension transfer specialists only.
That does not mean no CPD. The FCA’s advisers page says that if you carry out other retail activities, such as mortgage advice, you will need to carry out CPD for that activity as well, and firms remain responsible for maintaining the competence of everyone they assess as competent. Mortgage advice on regulated mortgage contracts for a non-business purpose also requires an appropriate qualification before the adviser can be assessed as competent; the FCA’s list in TC Appendix 4 includes CeMAP.
Insurance and protection: the 15-hour rule changed
Under the Insurance Distribution Directive rules, staff involved in insurance distribution were required to complete at least 15 hours of professional training or development a year. Many firms still describe it that way. It is now only partly true.
The FCA’s policy statement PS25/21 removed the mandatory 15-hour CPD requirement for general insurance and pure protection staff, with the instrument coming into force on 9 December 2025. The current position under SYSC 28.2 is:
- Long-term insurance staff (investment-type life policies and long-term care insurance) must still complete a minimum of 15 hours of professional training or development in each 12-month period.
- General insurance and pure protection staff have no fixed hours; guidance says they should undertake continued professional training and development.
If your firm’s training policy still applies 15 hours to a general insurance team, that is not a breach, just an internal standard above the regulatory minimum. But do not describe it to staff as an FCA requirement.
What qualifications do financial advisers need?
CPD maintains competence; it does not create it. Under TC 2.1.1R, a firm must not assess an employee as competent to carry on certain activities until they have attained each module of an appropriate qualification.
For retail investment advice, the FCA notes that the Level 4 Diploma became the standard when the Retail Distribution Review came into force at the start of 2013. The qualifying list is in TC Appendix 4. For mortgage advice on non-business regulated mortgage contracts, Appendix 4 lists approved qualifications including CeMAP.
No CPD course, including ours, substitutes for an appropriate qualification. CPD-accredited awareness courses are not regulated qualifications and do not appear on the FCA’s list.
What other training do advice firms need?
Beyond individual CPD, several firm-level duties effectively require training, and these apply to support staff as well as advisers.
Anti-money laundering
Regulation 24 of the Money Laundering Regulations 2017 requires relevant firms to ensure relevant employees are made aware of the law on money laundering and terrorist financing, are regularly given training in how to recognise and deal with transactions that may be related to money laundering, and to maintain a written record of the measures taken. Our guide to AML training requirements covers what “regularly” and “relevant employee” mean in practice, and what is anti-money laundering explains the basics.
Consumer Duty
The Consumer Duty rules in PRIN 2A do not themselves mention training. The expectation is in the FCA’s guidance, FG22/5, which says staff should be trained to be able to deliver good outcomes for customers, and lists training and competence records among the evidence firms can use to monitor outcomes. Put simply, if a firm cannot show its people understand the Duty, it will struggle to show the Duty is working.
Vulnerable customers
The FCA’s guidance on the fair treatment of vulnerable customers, FG21/1, says firms should ensure frontline staff have the necessary skills and capability to recognise and respond to a range of characteristics of vulnerability. For advice firms, clients whose health, capacity or circumstances are changing are exactly where that capability gets tested.
The certification regime
Under the Senior Managers and Certification Regime, certificates are valid for 12 months under section 63F of the Financial Services and Markets Act 2000, and the FCA expects annual re-certification to be proportionate. Training and CPD records are an obvious source of evidence when a firm makes that annual fitness and propriety assessment, which is one more reason to keep them tidy.
Data protection
Advice firms hold some of the most sensitive personal data any business handles: income, health for protection underwriting, family circumstances. UK GDPR’s accountability principle means being able to show staff understand how to handle it. See what is GDPR for the principles.
The CPD record mistakes that cause problems at verification
Most advisers who run into difficulty with CPD have done enough learning. The problem is almost always the record. The patterns worth avoiding:
Logging titles instead of outcomes
“Pensions webinar, 1 hour” tells an accredited body almost nothing. Structured CPD is defined by its learning outcome, so the record should say what the outcome was: “Updated understanding of the taxation of death benefits; revised the section of my suitability report template that covers beneficiary nominations.” The second version takes thirty seconds longer to write and survives a sample check.
Counting the same hours twice
An adviser who is also a pension transfer specialist, or who holds a professional body membership with its own CPD scheme, often has overlapping requirements. Whether one activity can count towards more than one scheme depends on each body’s rules. Check rather than assume, and never record more hours than you actually spent.
Leaving it all to the final month
Because the requirement runs over 12-month periods tied to verification, it is easy to find yourself a month before your SPS date with 14 structured hours and a diary full of client meetings. Cramming 7 hours of webinars into a fortnight satisfies the arithmetic but rarely changes practice, and a year of CPD concentrated in its final weeks is exactly the pattern that invites questions about relevance.
Only doing product CPD
Product and market knowledge matters, but the areas that generate complaints, file review findings and enforcement are usually conduct areas: suitability, vulnerability, disclosure, financial crime. A year’s record with no structured learning in any of them is a weaker record than its hours suggest.
Treating support staff as out of scope
Paraplanners, administrators and client service staff are not retail investment advisers, so TC 2.1.15R does not apply to them. But regulation 24 of the Money Laundering Regulations, Consumer Duty guidance and the vulnerable customers guidance all reach staff who deal with clients and their money. The firms that handle this well give the whole team a short annual baseline and keep one training record for everyone.
A practical CPD plan for a retail investment adviser
- Know your SPS date. Verification is due within 60 days of your competence anniversary. Put the date in your calendar two months ahead.
- Start from gaps, not offers. Review your last file checks and complaints. The weakest area is the first structured CPD topic.
- Book 21 structured hours early, spread across the year, each with a defined learning outcome.
- Cover the regulator’s themes. Consumer Duty, vulnerability and financial crime each deserve at least some structured time every year.
- Record unstructured learning weekly, with specific titles and a line on what changed.
- Write the reflection at the time. Verification and sample checks are far easier when the evidence was created as you went.
Other regulated professions run quite different systems. Accountants and solicitors, who often work alongside advisers, are covered in our guides to CPD for accountants and CPD for solicitors.
Which courses suit financial advisers and advice firms?
For advisers, paraplanners and support staff wanting structured awareness learning on the firm-level duties above:
- Anti-Money Laundering Awareness: red flags, suspicious activity reporting and regulation 24
- Data Protection and GDPR Awareness: client data, special category data and breaches
- Anti-Bribery Awareness: gifts, hospitality and the Bribery Act 2010
Those three together cost £18 rather than £27, because any three courses trigger the pay-for-2-get-3 offer. Add them to the cart and the discount applies automatically. For the vulnerability side, firms often add Dementia Awareness or Mental Health Awareness, and Cyber Security Awareness suits anyone handling client portals and payments.
Said plainly: these are CPD-accredited awareness courses. They are e-learning with a defined learning outcome and an assessment, which is the kind of activity FCA guidance describes as structured, but whether a given activity is relevant to your role and counts at verification is decided by you and your accredited body. They are not FCA-appropriate qualifications, and they do not issue or replace a Statement of Professional Standing.
Frequently asked questions
How many CPD hours does a financial adviser need?
Retail investment advisers must complete at least 35 hours of CPD in each 12-month period under FCA rule TC 2.1.15R. FCA guidance at TC 2.1.16G says at least 21 of those hours should be structured.
What is structured CPD for financial advisers?
FCA guidance describes structured CPD as activities such as courses, seminars, lectures, conferences, workshops, web-based seminars and e-learning, designed to achieve a defined learning outcome. Unstructured CPD includes research, reading relevant material and coaching or mentoring. All CPD should be relevant to the adviser's role and capable of independent verification.
What is a Statement of Professional Standing?
A Statement of Professional Standing (SPS) is issued by an FCA accredited body to verify a retail investment adviser's qualifications, CPD and annual declaration. It is valid for a maximum of 12 months. The three accredited bodies are the CISI, the CII and Walbrook Institute London, formerly the London Institute of Banking and Finance.
Do mortgage advisers have a CPD hours requirement?
The FCA's training and competence rules do not set a fixed number of CPD hours for mortgage advisers. Firms must still maintain their competence, and the FCA says advisers carrying out other retail activities such as mortgage advice need to carry out CPD for that activity.
Is the 15-hour insurance CPD requirement still in force?
Only for long-term insurance staff. The FCA's policy statement PS25/21 removed the mandatory 15-hour requirement for general insurance and pure protection staff from 9 December 2025. Long-term insurance staff must still complete at least 15 hours of professional training or development each year under SYSC 28.2.
Do financial advice firms need anti-money laundering training?
Firms within the Money Laundering Regulations 2017 must ensure relevant employees are made aware of the law and regularly trained to recognise and deal with transactions that may involve money laundering, and must keep a written record of the measures taken, under regulation 24.
Can an online CPD course replace an FCA-appropriate qualification?
No. CPD maintains competence but does not create it. A firm must not assess an adviser as competent until they have attained an appropriate qualification from the list in TC Appendix 4. CPD-accredited awareness courses are not on that list.
Compliance courses for advice firms
£9 per course. CPD accredited, 100% online, verifiable e-certificate. Pay for 2, get 3 — any 3 courses for £18.
This article is general information, not legal, regulatory or financial advice. FCA rules change, and the insurance CPD requirements were amended with effect from 9 December 2025; always check the current FCA Handbook and your accredited body’s requirements. A CPD awareness course is not an appropriate qualification for FCA purposes and does not replace a Statement of Professional Standing.