FCA CPD for advisers: 35 hours a year, structured vs unstructured

If you give retail investment advice in the UK, the headline rule is simple: according to the Financial Conduct Authority (FCA), advisers must complete a minimum of 35 hours of continuing professional development (CPD) each year for retail investment activities, and 21 of those hours should be structured. The remaining hours can be unstructured. This guide explains what each type means, how the CII and CISI apply the rule, and what you need to do to stay compliant. If you want wider context on CPD, our CPD hub is a good starting point.

The FCA 35 hours CPD requirement at a glance

The FCA's professional standards page for advisers sets out a small number of annual obligations. Together they make up the regime that sits behind the 35 hours:

• CPD: a minimum of 35 hours each year for retail investment activities, of which 21 hours should be structured.
• Statement of Professional Standing (SPS): advisers must hold an annual SPS issued by an accredited body, and firms must ensure their advisers have one.
• Qualifications: advisers must hold an appropriate qualification, as set out in TC Appendix 4 of the FCA's Training and Competence sourcebook.
• Ethical standards: advisers must make an annual declaration to their accredited body confirming compliance with the Statements of Principle for Approved Persons (APER).
• CPD declaration: a separate annual declaration confirms that you have met the CPD requirements for the previous 12 months.

The FCA page does not give a fixed calendar deadline. The requirements are annual: an SPS runs for a maximum of 12 months from the date of verification, and the CPD declaration looks back over the previous 12 months. Your accredited body will tell you the dates of its own CPD year.

Who the requirement applies to

Be precise about scope, because this is a common source of confusion. The FCA page is addressed to advisers, and the 35 hours is tied to retail investment activities. It is not a blanket requirement for every person working in an FCA-regulated firm.

The FCA also says that if you carry out other retail activities, such as mortgage advice or managing funds, you will need to carry out CPD for that activity as well. In other words, the 35 hours covers your retail investment advice work and does not automatically cover other regulated activities you perform.

One further point on scope. The CII's own scheme rules are a membership requirement. According to the CII, qualified CII, PFS and SMB members need to complete a minimum of 35 hours of compulsory CPD each year, at least 21 of which must be structured, whether they are based in the UK or outside it. So a CII member who does not give retail investment advice may still have a 35-hour obligation to the Institute, even though the FCA rule itself is about retail investment activities.

What counts as structured CPD

The FCA says structured CPD is an activity designed to achieve a defined learning outcome. Its examples include participating in courses, seminars and lectures, as well as conferences, workshops, web-based seminars and e-learning. The FCA adds that all CPD should be measurable and capable of being independently verified by an accredited body.

The accredited bodies give very similar definitions:

• CII: structured CPD is the undertaking of any formal learning activity designed to meet a specific learning outcome. Its examples include studying for an exam, seminars, lectures, conferences, workshops, courses and e-learning.
• CISI: structured CPD must be a purposeful learning activity, undertaken for the express purpose of learning. Its attended examples include training courses, seminars, workshops, conferences, exam training courses, lectures, professional forums and company briefings with an explicit briefing remit.

The common thread is intent and evidence. A structured activity has a learning objective set in advance, and you can show that you did it.

What counts as unstructured CPD

Unstructured CPD is the less formal learning that happens around your day job. The two bodies describe it like this:

• CII: unstructured CPD is any activity an individual considers has met a learning outcome. Its example is reading a trade publication that includes a technical article on a topic where you have a development need, as part of normal day-to-day work.
• CISI: unstructured CPD includes unplanned activities where there is no pre-determined learning objective and outcome. Its examples include informal meetings with no predetermined learning purpose, unverifiable podcasts and webcasts, television programmes on relevant topics, informal coaching and mentoring of staff on industry-relevant topics, and research. The CISI states that up to 14 unstructured hours can count towards the total, and that research is capped at 10 hours.

Note that the CISI treats unverifiable podcasts and webcasts as unstructured, so the same format can fall on either side of the line depending on whether it is verifiable and has a defined learning outcome.

Structured vs unstructured: a quick comparison

Recording your CPD and what to expect from an audit

Under the CII's scheme rules, you should record the time spent on each activity, keep a verifiable audit trail and reflect on whether the activity met your learning needs. Each activity must last at least 30 minutes, although shorter activities that address a single learning outcome can be combined. Evidence might include a training provider's certificate of attendance and the course syllabus. According to the CII, records are only submitted if requested, and about 10% of records are sampled each year.

The FCA page says accredited bodies check at least 10% of advisers' CPD records and can refer concerns to the FCA. The CISI also notes that CPD for members affected by the Retail Distribution Review must be relevant to the retail part of their role, so make sure your hours reflect the work you actually do.

A well-kept log is the simplest protection. Record the date, duration, topic, learning outcome and what you took from it, and file the certificate straight away.

Who are the accredited bodies?

According to the FCA, the accredited bodies for advisers are the Chartered Institute for Securities and Investment (CISI), the Chartered Insurance Institute (CII) and Walbrook Institute London Limited (formerly the London Institute of Banking and Finance Limited). They check that advisers hold appropriate qualifications, review a random sample of CPD records and share information with the FCA. Holding an SPS does not remove your firm's own duty to assess your competence.

Practical tips for meeting the 35 hours

• Plan the 21 structured hours first. They are the minimum that cannot be made up with informal learning, so schedule them early in your CPD year.
• Link learning to your role. Topics that connect to your client work, such as the FCA's Consumer Duty, are easier to justify and apply.
• Log as you go. Do not leave reflections until the end of the year.
• Check your body's rules. Your accredited body's CPD year and recording tool may differ from the FCA's summary, and some bodies set extra conditions.
• Do not rely on unstructured hours. They have a role, but a verifiable, structured activity is stronger evidence if your records are sampled.

For a general look at how the two types compare outside advice, see our guide to structured and unstructured CPD, and for background on the regulator, read our overview of the Financial Conduct Authority.

Frequently asked questions

How many CPD hours do FCA advisers need?

According to the FCA, advisers must complete a minimum of 35 hours of CPD each year for retail investment activities, of which 21 hours should be structured.

Does the 35 hours apply to everyone in an FCA-regulated firm?

No. The FCA page is addressed to advisers and the requirement is tied to retail investment activities. If you carry out other retail activities, such as mortgage advice or managing funds, you will need to carry out CPD for that activity as well.

Can I count reading or podcasts towards my hours?

They can count as unstructured CPD. The CII gives reading a relevant trade article as an example, and the CISI lists unverifiable podcasts and webcasts as unstructured. They cannot replace the 21 structured hours.

Is there a fixed deadline for the CPD declaration?

The FCA page does not set a calendar deadline. The declaration covers the previous 12 months, and your SPS lasts a maximum of 12 months from verification, so check the dates with your accredited body.

What do I need alongside CPD?

You must hold an annual SPS, an appropriate qualification under TC Appendix 4, and make an annual declaration of compliance with APER.

Final thoughts

The 35-hour rule is straightforward once you separate the two types: at least 21 hours of verifiable, outcome-led learning, with the rest made up of informal development you can still reflect on and record. Learnsignal has a growing library of CPD content, which you can explore through our CPD hub.

This article is general information only. It is not regulatory, legal or compliance advice. Always check the current FCA rules and your accredited body's CPD requirements, or speak to your compliance team, before relying on this guidance.