What the FCA Expects From Your Training and Competence Records

The FCA does not specify a system for holding training records. It specifies retention periods, and it sets three different ones that can run simultaneously inside the same firm, each starting from an event most systems do not track. That combination is where firms get caught.

Three clocks, one firm

TC 3.1.1R requires a firm to make “appropriate records to demonstrate compliance with the rules in this sourcebook”. The retention periods are:

• MiFID business — at least 5 years
• Non-MiFID business — 3 years
• Pension transfer specialists — indefinitely

Two things about that list matter more than the numbers.

First, the periods run from the date the employee stops carrying on the activity, not from the date of the training. So the retention clock is driven by a workforce event, and a system that deletes leavers or archives them without a cessation date cannot calculate when a record may lawfully be destroyed. Leaver management, not training management, is what determines compliance here.

Second, pension transfer specialists are the only category with an indefinite period. A single individual in that role turns part of your training archive into a permanent record, and a retention rule configured globally at three or five years will quietly destroy evidence the firm is required to hold forever.

Insurance distribution adds a fourth set of rules

For insurance distribution the requirements sit in SYSC 28.4, and they are more prescriptive than TC.

SYSC 28.4.1R requires a firm to “establish, maintain and keep appropriate records to demonstrate compliance with this chapter” — and, separately, to be able to give the FCA on request the name of the person responsible for that record-keeping requirement. That is an accountability field, not a document: somebody owns the records and the firm must be able to name them on demand.

SYSC 28.4.2R requires an up-to-date record of the continued professional training or development completed by each long-term insurance employee in each 12-month period, retained for not less than 3 years after that person stops carrying on the activity. The firm must be able to provide any version of the record to the FCA on request.

“Any version” is the demanding phrase. It implies version history rather than current state — the firm must be able to reproduce what the record said at a previous point, which rules out a system that simply overwrites a completion field.

The employee has a right to their own record

Two rules are easy to miss and awkward to retrofit. SYSC 28.4.3R provides that a firm must not prevent a non-investment insurance employee from obtaining a copy of their records, and SYSC 28.4.4R does the same for long-term insurance employees in respect of the SYSC 28.4.2R record.

In practice that is a self-service export requirement. An adviser moving firms, or evidencing their own competence to a professional body, is entitled to their record, and a platform that only produces manager-level reports puts the firm on the wrong side of a rule it probably does not know exists.

What this means as a specification

Translating the rules into what a system must hold and produce:

• A business-type flag per person, distinguishing MiFID from non-MiFID activity, because the retention period follows the activity rather than the firm
• A cessation date per activity, not just a leaving date — someone may stop carrying on one activity while remaining employed
• A permanent-retention marker for pension transfer specialists, immune to global retention policies
• Twelve-month period records for long-term insurance employees, aligned to the period rather than to a rolling total
• Version history, so any previous version of a record can be produced to the FCA
• A named owner of the record-keeping requirement, retrievable on request
• Individual self-service export, so an employee can obtain their own record
• Evidence of the competence assessment itself, since TC 3.1.1R requires records demonstrating compliance with the whole sourcebook, not only training completion

That last point is the one most often missed. TC is a competence regime, not a training regime. Records showing that courses were completed do not by themselves demonstrate that the firm assessed competence, supervised an employee until they were assessed as competent, or maintained that competence afterwards. The continuing professional development side of this — including the structured and unstructured split for retail investment advisers — is covered in our guide to the FCA’s 35-hour CPD requirement.

Why retention is the hardest part

Most firms can produce a completion report. Far fewer can answer the question an FCA supervisor is actually likely to ask: show me the training and competence record for an adviser who left four years ago, as it stood at the point they were signed off as competent.

Answering that requires the cessation date, the business-type flag, the version history and a retention rule that did not delete the record at the three-year mark because the individual turned out to be doing MiFID business. Each element is trivial on its own. The combination is where systems fail, and it fails silently, because nobody discovers a deleted record until it is needed.

The same structural pattern applies in healthcare, where CQC derives system requirements from its own records and staffing regulations — see our guide to what CQC expects from a training records system. The regulators differ; the lesson does not. Design against the retention and evidence rules, not against the course catalogue. Our CPD course library covers the training that populates these records.

Frequently asked questions

How long must training and competence records be kept?

Under TC 3.1.1R, at least five years for MiFID business, three years for non-MiFID business, and indefinitely for pension transfer specialists — each period running from when the employee stops carrying on the activity rather than from the date of training.

Which records attract indefinite retention?

Those relating to pension transfer specialists. They are the only category in TC 3.1.1R subject to an indefinite period, which means a global retention policy set at three or five years will destroy records the firm must keep.

Can an employee demand a copy of their training record?

Effectively yes. SYSC 28.4.3R and SYSC 28.4.4R provide that a firm must not prevent an insurance employee from obtaining a copy of their records, so the firm needs a route for individuals to get them.

What does “any version of the record” require?

SYSC 28.4.2R requires a firm to be able to provide any version of the continuing professional training record to the FCA on request, which implies retaining prior versions rather than only the current state.

Is a completion report enough to satisfy TC?

No. TC 3.1.1R requires appropriate records to demonstrate compliance with the whole sourcebook, which includes assessing competence, supervising employees until assessed as competent, and maintaining competence — none of which a completion report evidences on its own.