Briefing: Maintaining competence is key in driving up standards of professionalism

We all engage with professionals as we go about our lives. We rely upon their expertise and knowledge and trust in the advice and services they deliver.

It therefore follows that we assume they are dedicated to maintaining their standards of professionalism through keeping their competences, skills and knowledge up to date.

Last month (May 2025), the FCA issued its consultation paper entitled Simplifying the insurance rules (CP25/12), which outlined proposals that are “intended to ensure the delivery of proportionate regulation that removes barriers to innovation and promotes effective competition in the insurance market in the interests of consumers”.

Now, there is nothing in that statement that can reasonably be considered objectionable and, in truth, as a statement, it is clearly aligned to the FCA’s 2025 to 2030 five-year strategy. Published in March 2025, this prioritises growth.

Among the proposals that the FCA is consulting on is one that relates to training and competency requirements. Here, the FCA is exploring removing the regulatory requirement for people working in general insurance to complete 15 hours of ongoing training every year.

When the Chartered Insurance Institute (CII) first read this, we wondered initially whether the regulator was having second thoughts about the value of education and training.

The CII firmly believes that education and training are vital ingredients in driving up professional standards, as well as enabling trust in the insurance profession. Continued learning does this by:

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

There appears to be a mismatch between the FCA’s proposal to remove the annual 15 hours of ongoing training requirement and its views on professional standards.

For example, it is clear that the FCA’s obligation for individuals working in insurance to “possess appropriate knowledge and ability in order to complete their tasks and perform their duties adequately” is not being called into question.

Moreover, within the consultation document, the FCA references feedback it has received that clearly suggests there is a culture of learning and development prevalent within the sector that renders the FCA’s monitoring and record keeping requirements as burdensome and adding no benefit.

High expectations

While the idea of scrapping the 15-hour training requirement may reduce the regulatory burden superficially, the high-level standard that professionals are held to is still very demanding.

The regulator’s expectations of insurance professionals will remain the same. As will the expectations of consumers, which further reinforces why a commitment to the maintenance of high standards of professionalism is so important.

To that end, continuous professional development (CPD) is a crucial element of professionalism because it allows individuals to adapt to a constantly changing technological, economic and social environment.

While we all learn by experience, professional development gives structure to the learning process by setting objectives, identifying relevant learning opportunities and introducing the discipline of reviewing what has been learnt and identifying remaining knowledge gaps.

Doing the right thing

As a professional body, we have always had the ability to set our own standards for our members.

While these have often aligned with the standards set by the regulator, we have typically instigated standards that 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 competency framework and career development tool, 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 back in 2005 to a 15-hour CPD requirement, which came into effect with the Insurance Distribution Directive in 2018.

We responded to the FCA’s original call for input and will be responding to the wider consultation before the 2 July 2025 response deadline.

We noted in our initial response that there will always be a balance to be struck between regulation and the responsibility on professionals to do the right thing.

By supporting our members to achieve this balance, we give the FCA the freedom to focus on creating and enforcing detailed rules where competitive pressures make other voluntary arrangements difficult to sustain.