Insurance Broking CPD: The 15 Hours, Who It Actually Applies To, and How Ireland Differs

Almost every insurance broker has heard that there is a 15-hour annual training requirement. Far fewer can say which rule imposes it, which of their staff it binds, or why the answer is different in Dublin and London. The difference matters: in the UK the 15-hour rule in one sourcebook catches a narrower group than firms assume, while in Ireland commercial general insurance is squarely inside the competency regime.

This guide sets out the rule references for both jurisdictions so that a compliance officer can check them rather than take them on trust.

The UK: four regimes, and they bite differently

Four things apply to a UK insurance intermediary, and conflating them is the usual source of error.

First, the Training and Competence sourcebook. It applies where an employee carries on an activity listed in TC Appendix 1 for retail clients, customers or consumers, subject to the limitations in the appendices. It supplements the competent employees rule, and it defines competence as skills, knowledge and expertise, including good ethical behaviour.

Second, SYSC 28, headed Insurance Distribution: Specific Knowledge, Ability and Good Repute Requirements. It applies to a firm with Part 4A permission carrying on insurance distribution activities.

Third, TC 4.2, which specifies how the TC rules are modified for firms carrying on insurance distribution activities.

Fourth, the Senior Managers and Certification Regime and the Consumer Duty, neither of which contains an insurance-specific competence rule.

General insurance broking is inside TC but outside the qualification requirement

This is the point most often got wrong, in both directions. General insurance broking is not exempt from the Training and Competence sourcebook. But the activity that covers it — TC Appendix 1 Activity 24, giving personal recommendations on non-investment insurance contracts to a consumer — carries a qualification requirement of "No".

So there is no mandatory examination for a general insurance adviser in the way there is for a retail investment adviser. There is no appendix entry referring specifically to general insurance at all. What there is instead is a competence obligation without a prescribed qualification, which places the whole weight on the firm’s own assessment and record.

Insurance-adjacent activities that do carry a qualification requirement are worth knowing because brokers drift into them: long-term care insurance contracts, Friendly Society tax-exempt policies, and administrative functions in relation to life policies.

The 15 hours: two routes, and only one is universal

There are two separate provisions imposing 15 hours, and they catch different people.

The SYSC route is narrow. SYSC 28.2.1R(3) requires that where a firm has long-term insurance personnel, each long-term insurance employee completes a minimum of 15 hours of professional training or development in each 12-month period. Long-term insurance personnel means people directly involved in insurance distribution for long-term insurance contracts other than pure protection contracts, long-term care insurance contracts, or rights to or interests in a life policy — plus those in the management structure responsible for them and those supervising them.

For non-investment insurance personnel, the position is different. SYSC 28.2.1R(1) applies the knowledge-and-ability duty to them, but the continued-training provisions at 28.2.1R(2) to (4) do not. Instead, SYSC 28.2.1A G states that the FCA expects continued training and development in line with the competent employees rules. That is guidance, not a fixed hour count.

The TC route is broader. TC 2.1.15R sets 35 hours of continuing professional development for retail investment advisers, and TC 4.2.5R modifies it: for relevant employees who are not also retail investment advisers, the rule applies as if "35 hours" read "15 hours". Where a relevant employee is also a retail investment adviser, the 35 hours must include a minimum of 15 hours covering the professional knowledge requirements at SYSC 28.2.3R.

"Relevant employees" under TC 4.2.3R means those directly involved in carrying on the firm’s insurance distribution activities, those in the management structure responsible for them, and those responsible for supervising them. That definition is not limited by product type, which is why most firms land on 15 hours as the practical answer — but TC’s own gateway is activities carried on for retail clients, customers or consumers, so the position for a broker with no retail or consumer business is genuinely arguable and depends on the appendices.

Both routes extend beyond employees in the narrow sense. SYSC 28.1.3R and TC 4.2.4R reach people placed at the firm’s disposal by a third party, and appointed representatives and their employees.

Records, and the three-year rule

SYSC 28.4.2R requires an up-to-date record of each long-term insurance employee’s continued training for each 12-month period, retained for not less than three years after the person stops the activity. TC 3.1.1R, as amended for insurance distribution, imposes the equivalent record and retention requirement for relevant employees, and requires any version to be provided to the FCA on request.

SYSC 28.4.3R and 28.4.4R add a point firms sometimes overlook: a firm must not prevent employees from obtaining copies of their own records.

There is no fixed CPD year in the Handbook. It says only "each 12 month period", which means the firm chooses, and should then apply it consistently. TC 2.1.17R suspends the CPD requirement during continuous absence for maternity, paternity or adoption leave, long-term illness or disability, caring responsibilities, or equality-and-diversity-related absence.

SMCR: the carve-out brokers should know

The certification regime was extended to solo-regulated firms in December 2019, with three categories — Limited Scope, Core and Enhanced — which firms self-classify under the rules. Certification requires a firm to be satisfied a person is fit and proper, and in assessing that the FCA says to have regard to whether the person has obtained a qualification, undergone or is undergoing training, possesses a level of competence, or has the required personal characteristics. Certificates are valid for 12 months.

The carve-out worth knowing is SYSC 27.8.19R: the client-dealing function excludes advising on a non-investment insurance contract, and excludes dealing in or arranging deals in such contracts. So client-facing general insurance staff are generally not caught by that certification function — which is another reason the firm’s own competence framework, rather than a regulatory certificate, is doing the work.

On the Consumer Duty, there is no competence rule as such. The nearest hooks are PRIN 2A.8.1R(1), requiring the Duty to be reflected in strategies, governance, leadership and people policies including incentives at all levels, and PRIN 2A.8.2G, stating that a firm should not use staff incentives, performance management or remuneration structures in a way that conflicts with its obligations.

Ireland: a wider net, and a harder 15 hours

The Irish regime is more prescriptive, and the scope is broader in one decisive respect.

The instruments are the Minimum Competency Code 2017 and the Minimum Competency Regulations 2017, both of which took effect on 3 January 2018, replacing the former Code. The current version is the 2017 Code as amended by addenda, including one effective from 1 October 2024 which extended the standards to credit union services, inserted a transitional provision for credit union staff working toward a recognised qualification, and added recognised qualifications — without changing the CPD hours.

The Code lists eight categories of retail financial product: life assurance; pensions; savings and investments; personal general insurance; commercial general insurance; private medical insurance and associated insurances; mortgage credit agreements, housing loans, home reversion agreements and associated insurances; and consumer credit agreements and associated insurances.

Note category five. Commercial general insurance is expressly a retail financial product category in Ireland. That is the single biggest structural difference from the UK, where the Training and Competence gateway is framed around retail clients, customers and consumers, and where commercial lines sits outside much of it.

The CPD requirement sits at section 1.7.1 of the Code. Holders of a recognised qualification whose maintenance does not depend on CPD must complete 15 hours of CPD each year, and grandfathered persons must also complete 15 hours a year. Within that: at least one hour per year for each function, at least one hour relating to ethics, no carry-forward of surplus hours, and a shortfall that may be made up by the end of the following year provided no other shortfall occurred in the previous five years. Where a recognised qualification carries a professional designation whose maintenance depends on CPD, completing that scheme’s requirements satisfies the Code.

Separately, board members of a mortgage credit intermediary who do not carry out a relevant mortgage credit function must complete six hours of CPD a year relating to mortgage credit agreements.

The statutory basis for 15 hours is the European Union (Insurance Distribution) Regulations 2018, whose Regulation 20(2)(b) requires the Central Bank to have in place and publish mechanisms to control and assess the knowledge and competence of insurance and reinsurance intermediaries based on not less than 15 hours of professional training or development per year. Note the framing: that duty sits on the Central Bank, and the Code is how it is delivered. The two are aligned at 15 hours and are not cumulative — the Minimum Competency Regulations cross-refer to "15 hours of CPD, as required by the Minimum Competency Code".

Two further Irish points with operational bite. New entrants have four years from commencing the relevant function to obtain the qualification, with an additional six months’ relevant experience required for MiFID services. And firms must monitor compliance at least once within the first nine months of each year and once no later than six weeks after year end — a scheduling requirement, not just a records one.

On the CPD year: the Code itself does not define it. The professional bodies operate it as the calendar year. The Insurance Institute of Ireland requires 15 hours of formal CPD in each calendar year, completed by midnight on 31 December and logged and submitted by midnight on 31 January following; the Institute of Banking operates the same year with an annual return due by 31 January.

Qualifications and professional bodies

In the UK the Chartered Insurance Institute ladder runs from the Certificate in Insurance at Level 3, requiring a minimum of 40 CII credits, to the Advanced Diploma in Insurance at Level 6, requiring a minimum of 290 credits of which at least 150 must be at Advanced Diploma level, with a total qualification time of 660 hours. Between them sits the Diploma, which the CII describes as a Level 4 qualification. The CII’s own CPD scheme requires a minimum of 35 hours each year, of which at least 21 hours must be structured, for qualified members — a higher bar than the regulatory 15, and the reason many brokers meet the FCA requirement incidentally.

In Ireland, recognised qualifications are listed at Appendix 4 of the Code, and recognised awarding bodies include the Insurance Institute of Ireland, the Institute of Banking, LIA, the National College of Ireland and others. Section 1.7.3(a) of the Code allows a person to join a CPD scheme run by an external professional educational body provided it does not differ materially from the Code’s requirements — so the Code names no single approved scheme.

Brokers Ireland is a representative body rather than a regulator, representing over 1,200 firms and providing training and compliance support; the Central Bank remains the regulator.

Frequently asked questions

Does every UK insurance broker need 15 hours a year?

Not under SYSC 28, which applies the 15-hour rule only to long-term insurance personnel. The broader route is TC 2.1.15R as modified by TC 4.2.5R, which applies 15 hours to relevant employees who are not retail investment advisers. For non-investment insurance personnel the FCA expresses an expectation rather than a fixed number.

Is there a qualification requirement for general insurance advice in the UK?

No. TC Appendix 1 Activity 24 carries a qualification requirement of "No". The obligation is competence, assessed and recorded by the firm.

Is commercial lines inside the Irish regime?

Yes. Commercial general insurance is category five of the eight retail financial product categories in the Minimum Competency Code.

How many Irish CPD hours, and what must they include?

Fifteen a year, including at least one hour per function and at least one hour on ethics, with no carry-forward.

Do the Irish 15 hours stack on top of the Insurance Distribution Regulations?

No. They are the same 15 hours. The Regulations place the duty on the Central Bank and the Code delivers it.

How long must training records be kept?

In the UK, not less than three years after the person stops carrying on the activity.

Running it properly

For a firm operating in both jurisdictions the practical answer is usually to run the Irish standard everywhere: 15 hours, at least one hour of ethics, at least one hour per function, no carry-forward, calendar year, monitored twice a year. That satisfies the UK requirement comfortably and removes the need to maintain two schemes.

Learnsignal builds CPD and compliance training for regulated financial services teams, with records designed for a regulator rather than reconstructed for one — including the AML and beneficial ownership content that sits alongside competence obligations, the ethics hour covered by our speak up and whistleblowing material, and data protection duties in our GDPR compliance checklist. Firms building a formal framework may also want our guide to ISO 37301. To see the catalogue, explore our CPD courses or see pricing for teams.