The FCA's TC Sourcebook Has One Central Requirement: Firms Must Be Able to Prove Their People Are Competent. Most Firms Can't.
Having trained people and being able to demonstrate to the FCA that your people are competent are two entirely different things. The TC Sourcebook doesn't just require firms to train staff — it requires systematic competence assessment before unsupervised regulated activity, structured supervision calibrated to individual competence levels, mandatory qualifications aligned to TC Appendix 1, CPD hours that vary by regulated activity, comprehensive records retained for six years, and the same standards applied to contractors and appointed representatives as to permanent employees. A training completion spreadsheet isn't a Training and Competence framework. When the FCA comes in — through a supervisory visit, a thematic review, or following a complaint — it looks for documented evidence that individuals were assessed as competent before they performed regulated functions independently, that supervision was appropriate to their stage of development, and that ongoing CPD demonstrates sustained competence over time. Gaps in any of those three areas generate findings. This comprehensive Training and Competence Policy gives FCA-regulated firms across every sector a complete T&C framework covering the full competence lifecycle — from induction and initial assessment through qualifications, CPD, supervision, regulatory change updates, competence gap remediation, contractor oversight, and record-keeping — built to satisfy TC Sourcebook requirements and withstand regulatory scrutiny.
Incompetence isn't just a training failure. Under SMCR, it's an accountability failure.
What's included: Full regulatory mapping — TC Sourcebook (competence assessment/qualification requirements/supervision/CPD/record-keeping), TC 2.1.17R (record-keeping specific requirements), TC Appendix 1 (qualification standards by regulated activity), SYSC (governance/oversight arrangements), COBS (investment services), ICOBS (insurance intermediation), MCOB (mortgage and home finance), CONC (consumer credit), SM&CR SYSC 24-27 (SMF accountability), FSMA 2000 · Multi-sector qualification framework — investment advisers and managers (CII/LIBF/TC Appendix 1 compliant/70%+ pass standard), insurance intermediaries (product knowledge/needs analysis/general insurance/life/protection), consumer credit (creditworthiness/affordability/regulatory compliance), payment services (AML/fraud prevention/operational risk), debt management (vulnerable customer training), funeral plans (FPCOBS requirements) · Three-tier supervision intensity model — Close Supervision (daily interaction/all activities reviewed — new starters/competence assessment/performance gaps), Regular Supervision (structured weekly/periodic file reviews — competent with track record), General Supervision (monthly structured/quarterly comprehensive — highly experienced) · CPD mandatory hours by sector — investment advisers/managers (35 hours annually/21 structured), insurance intermediaries (35 hours/21 structured), consumer credit (15 hours), payment services (20 hours/regulatory and operational focus), debt management (20 hours/vulnerable customer training), funeral plans (15 hours) · Competence assessment framework — written examinations/practical assessments/oral examinations/portfolio-based/case study/role-specific simulations — 80% minimum pass rate/independent verification by assessors not involved in training · Four-level regulatory change classification — Critical (24-hour communication/mandatory briefing), High (5 working days/structured training), Medium (15 working days/knowledge update materials), Low (monthly cycle/information bulletin) · Competence Improvement Plan (CIP) — five-day assessment/ten-day CIP development/monthly progress reviews/escalation to disciplinary if unsatisfactory — with immediate risk mitigation: enhanced supervision/temporary permission withdrawal/restricted activities/additional quality checks · Record-keeping schedule — individual training records 6 years from cessation/competence assessments 6 years from date/CPD records 6 years/training programme materials 6 years from last use · KPI framework — training completion 100%/competence assessment pass rates 85% first attempt/CPD compliance 100%/time to competence within 12 months · Contractor and AR equivalence — same competence standards as permanent employees/same initial assessment/same CPD requirements/same supervision — plus AR-specific due diligence on their own T&C frameworks and compliance systems · Full glossary aligned to FCA Handbook definitions
Built for: Compliance Officers, SMF16 holders, T&C managers, HR Directors, and line managers at FCA-regulated firms across all sectors who need a complete TC Sourcebook-aligned Training and Competence Policy that covers every stage of the competence lifecycle, meets regulatory record-keeping requirements, and produces the documented evidence the FCA expects to see during supervisory review.
The FCA's TC Sourcebook Has One Central Requirement: Firms Must Be Able to Prove Their People Are Competent. Most Firms Can't.
Having trained people and being able to demonstrate to the FCA that your people are competent are two entirely different things. The TC Sourcebook doesn't just require firms to train staff — it requires systematic competence assessment before unsupervised regulated activity, structured supervision calibrated to individual competence levels, mandatory qualifications aligned to TC Appendix 1, CPD hours that vary by regulated activity, comprehensive records retained for six years, and the same standards applied to contractors and appointed representatives as to permanent employees. A training completion spreadsheet isn't a Training and Competence framework. When the FCA comes in — through a supervisory visit, a thematic review, or following a complaint — it looks for documented evidence that individuals were assessed as competent before they performed regulated functions independently, that supervision was appropriate to their stage of development, and that ongoing CPD demonstrates sustained competence over time. Gaps in any of those three areas generate findings. This comprehensive Training and Competence Policy gives FCA-regulated firms across every sector a complete T&C framework covering the full competence lifecycle — from induction and initial assessment through qualifications, CPD, supervision, regulatory change updates, competence gap remediation, contractor oversight, and record-keeping — built to satisfy TC Sourcebook requirements and withstand regulatory scrutiny.
Incompetence isn't just a training failure. Under SMCR, it's an accountability failure.
What's included: Full regulatory mapping — TC Sourcebook (competence assessment/qualification requirements/supervision/CPD/record-keeping), TC 2.1.17R (record-keeping specific requirements), TC Appendix 1 (qualification standards by regulated activity), SYSC (governance/oversight arrangements), COBS (investment services), ICOBS (insurance intermediation), MCOB (mortgage and home finance), CONC (consumer credit), SM&CR SYSC 24-27 (SMF accountability), FSMA 2000 · Multi-sector qualification framework — investment advisers and managers (CII/LIBF/TC Appendix 1 compliant/70%+ pass standard), insurance intermediaries (product knowledge/needs analysis/general insurance/life/protection), consumer credit (creditworthiness/affordability/regulatory compliance), payment services (AML/fraud prevention/operational risk), debt management (vulnerable customer training), funeral plans (FPCOBS requirements) · Three-tier supervision intensity model — Close Supervision (daily interaction/all activities reviewed — new starters/competence assessment/performance gaps), Regular Supervision (structured weekly/periodic file reviews — competent with track record), General Supervision (monthly structured/quarterly comprehensive — highly experienced) · CPD mandatory hours by sector — investment advisers/managers (35 hours annually/21 structured), insurance intermediaries (35 hours/21 structured), consumer credit (15 hours), payment services (20 hours/regulatory and operational focus), debt management (20 hours/vulnerable customer training), funeral plans (15 hours) · Competence assessment framework — written examinations/practical assessments/oral examinations/portfolio-based/case study/role-specific simulations — 80% minimum pass rate/independent verification by assessors not involved in training · Four-level regulatory change classification — Critical (24-hour communication/mandatory briefing), High (5 working days/structured training), Medium (15 working days/knowledge update materials), Low (monthly cycle/information bulletin) · Competence Improvement Plan (CIP) — five-day assessment/ten-day CIP development/monthly progress reviews/escalation to disciplinary if unsatisfactory — with immediate risk mitigation: enhanced supervision/temporary permission withdrawal/restricted activities/additional quality checks · Record-keeping schedule — individual training records 6 years from cessation/competence assessments 6 years from date/CPD records 6 years/training programme materials 6 years from last use · KPI framework — training completion 100%/competence assessment pass rates 85% first attempt/CPD compliance 100%/time to competence within 12 months · Contractor and AR equivalence — same competence standards as permanent employees/same initial assessment/same CPD requirements/same supervision — plus AR-specific due diligence on their own T&C frameworks and compliance systems · Full glossary aligned to FCA Handbook definitions
Built for: Compliance Officers, SMF16 holders, T&C managers, HR Directors, and line managers at FCA-regulated firms across all sectors who need a complete TC Sourcebook-aligned Training and Competence Policy that covers every stage of the competence lifecycle, meets regulatory record-keeping requirements, and produces the documented evidence the FCA expects to see during supervisory review.
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