Some useful insights here;
A year after the FCA scrapped the 15-hour minimum, firms still need to prove their people are competent – and a training log alone won’t do it.
Insurers have never had more data on employee learning and development, yet logged CPD hours and course completions still say very little about whether anyone is better at their job. While these metrics show that employees are participating in learning, they provide only limited evidence that skills and judgement have developed to the necessary standards to perform roles effectively.
This issue has become increasingly relevant following the FCA’s publication of PS25/21, which removed the mandatory 15-hour CPD requirement for insurance professionals, and the requirement to evidence competence. Firms are no longer required to focus on the minimum number of hours; however, they remain responsible for ensuring employees are competent to perform in their roles. In practice, this shifts the burden from ticking off hours to proving substance.
Qualified insurance professionals who are members of professional bodies must still meet their own continuing professional development obligations, which typically require 35 hours of CPD annually. Yet as firms focus on the return on their training spend, James Read, Managing Director at Zing365, believes it’s time to stop just counting hours and start measuring change.
“Numbers can tell you how much training someone has completed, but they’re static measures that don’t necessarily tell you what has changed as a result. In essence, they’re a useful baseline, but too many insurance firms treat them as the finish line.
“The true value lies in whether employees have retained the knowledge, whether they can apply it and whether it is contributing to better performance. Until firms can answer those questions, they’re measuring effort and calling it progress.”
The timing matters because the work itself is changing. As automation and AI absorb more repetitive, rules-based tasks, what’s left for people are the harder calls: weighing risk, interpreting complex claims, advising clients and spotting what the data doesn’t show. Those skills are what will set firms apart yet are much more difficult to evidence.
Read therefore believes that modern learning and development must focus on demonstrating competence. Measures such as knowledge retention, assessment performance, scenario-based question results, recurring skills gaps and the application of learning in day-to-day work can provide a far clearer picture of capability than training logs alone.
“CPD hours are easy to log, easy to audit and easy to put in a report. That’s why they’ve become the default way the insurance sector shows its people are developing. But like any vanity metric, they flatter the numbers without explaining what’s behind them.
“An hour of training can’t say whether the knowledge was retained, whether it changed how someone advises a client, or whether gaps have been closed. And you certainly can’t prove good judgement with an attendance record. Scenario-based assessments are particularly valuable because they test how employees apply knowledge and judgement in realistic situations, rather than simply what information they can recall.”
“CPD frameworks have a clear purpose in setting a baseline for professional development, and they shouldn’t be abandoned. The real change should come from how we interpret training data and measure its success.”
Read concludes: “The most useful question a firm can ask is whether the training shows up in the work. If you can link learning data to document reviews, quality assurance results and complaints, you can see how the training is manifesting when it comes to customers.”
“Regulators are increasingly interested in evidencing outcomes. The firms that can directly demonstrate competence will be in a much stronger position.”


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