Becoming a Mortgage or Equity Release Adviser: What the FCA Requires

To advise on mortgages or equity release in the UK you need an appropriate qualification, and the FCA defines precisely which ones count. The list sits in TC Appendix 4, organised by activity number, and it operates a combination system that catches people out: some qualifications satisfy the requirement on their own, others only in pairs, and a few only in sets of three.

Find your activity number first

TC Appendix 4 is indexed by activity, not by job title. The mortgage and equity release activities are:

• Activity 20 — advising on a regulated mortgage contract for a non-business purpose, and arranging certain execution-only sales of one
• Activity 21 — advising on equity release transactions, and arranging certain execution-only sales
• Activity 21A — designing scripted questions for an execution-only sale of a regulated mortgage contract for a non-business purpose
• Activity 22 — designing scripted questions for an execution-only sale of an equity release transaction
• Activity 23 — overseeing non-advised equity release sales on a day-to-day basis

Note that equity release is a separate activity from mortgage advice. A qualified mortgage adviser is not thereby qualified to advise on equity release, which is the single most common misunderstanding in this area.

The qualifications that count for mortgage advice

For Activity 20, TC App 4.1 Part 2A lists, among others:

• Certificate in Mortgage Advice and Practice (Post 01/11/2004) — key 1
• Certificate in Mortgage Advice — key 1
• CeMAP Bridge paper plus entry requirements — key 1
• Diploma for Mortgage Advice and Practice (DipMAP), plus entry requirements — key 1
• Chartered Insurance Institute Certificate in Advanced Mortgage Advice — key 1
• Certificate in Mortgage Advice – Paper 1 — key 3, covering activities 20 and 21
• Certificate in Mortgage Advice and Practice (Post 01/11/2004) – Paper 1 — key 3, covering activities 20 and 21

The key system is where candidates go wrong

Under TC App 4.1.1B the keys determine whether a qualification stands alone:

• Key 1 — the qualification alone fully meets the requirement
• Keys 2 and 3 — must be combined with a qualification of the other key
• Keys 4, 5 and 6 — each needs a combination of three qualifications

So holding “Paper 1” of a mortgage certificate is a key 3 qualification and does not by itself satisfy Activity 20. It has to be paired. Anyone who has passed part of a qualification and assumed they are qualified should check which key their award carries before advising.

Equity release has its own list

For Activities 21, 22 and 23, Part 2A lists:

• Certificate in Equity Release (Post 01/05/2007) — key 1, covering activities 21, 22 and 23
• Certificate in Regulated Equity Release, formerly known as the Certificate in Lifetime Mortgages — key 1 for activities 21 and 22, with activity 23 attracting keys 4, 5 and 6

That last line matters for anyone supervising non-advised equity release sales. Where activity 23 attracts keys 4, 5 and 6, the requirement is satisfied only by a combination of three qualifications — a materially higher bar than advising.

Qualifications that are closed but still valid

Part 2B separately lists mortgage and equity release qualifications no longer offered to new entrants — the Mortgage Advice and Practice Certificate, closed to new entrants in 2018, among them.

This is a useful distinction for experienced advisers. A qualification being withdrawn does not invalidate it for those who already hold it; it simply cannot be obtained by anyone new. A firm assessing an experienced hire should check Part 2B as well as Part 2A rather than assuming an unfamiliar award is insufficient.

A naming change worth knowing

The awarding body for several of these qualifications has been renamed. The London Institute of Banking & Finance became Walbrook Institute London, with the change effective from 2 April 2025.

Two practical points follow. Earlier qualifications remain valid and recognised, and no action is required of holders. And the LIBF name continues to be used for professional qualifications in financial and mortgage advice, and in trade and transaction banking — so a mortgage qualification certificate may legitimately carry either name depending on when it was awarded. For the current module structure and assessment format of any specific qualification, check with the awarding body directly rather than relying on third-party summaries, which have not always kept pace.

The qualification is the start, not the end

An appropriate qualification satisfies one element of the Training and Competence regime. The firm must still assess competence, supervise the individual until they are assessed as competent, maintain that competence, and keep records demonstrating all of it — retained for three years after the person stops the activity for non-MiFID business. Our guide to FCA training and competence records covers the evidential side.

The conduct rules an adviser then works to have changed recently and significantly: the interaction trigger that automatically made a sale advised has been removed, and affordability rules for term reductions and remortgaging were relaxed. Our guide to MCOB after the Mortgage Rule Review sets out what changed and what did not. Our CPD course library covers the continuing development that follows qualification.

Frequently asked questions

Does CeMAP qualify me to advise on equity release?

No. Equity release advice is Activity 21, with its own qualification list including the Certificate in Equity Release and the Certificate in Regulated Equity Release. Mortgage advice qualifications under Activity 20 do not cover it, although the “Paper 1” variants are listed against both activities as key 3 awards.

What does a “key 1” qualification mean?

That it fully meets the appropriate qualification requirement on its own. Keys 2 and 3 must be combined with a qualification of the other key, and keys 4, 5 and 6 each require a combination of three qualifications.

Is my qualification still valid if it is no longer offered?

Generally yes. TC App 4.1 Part 2B lists qualifications that are closed to new entrants but still recognised for the relevant activity, such as the Mortgage Advice and Practice Certificate, closed in 2018.

Who awards CeMAP now?

The London Institute of Banking & Finance was renamed Walbrook Institute London with effect from 2 April 2025, and the LIBF name continues in use for professional qualifications in financial and mortgage advice. Existing qualifications remain valid and no action is needed by holders.

What qualification does a supervisor of non-advised equity release sales need?

More than an adviser. Activity 23 covers overseeing non-advised equity release sales on a day-to-day basis, and where the qualification listed attracts keys 4, 5 and 6, the requirement is met only by a combination of three qualifications.