According to the FCA handbook, a firm must:
The exact start date of a 12-month period is not specified and therefore is at your discretion.
This may be the date the IDD came into force, 1st October 2018, therefore the full 15 hours CPD should be complete by 30th September 2019.
Alternatively, if you have chosen a different date, e.g. your accounting reference date, then you should have completed at least a pro-rata amount of CPD and have evidence that your employees are working towards/have completed the 15-hour target.
For example, if your 12-month period was to run 1st January – 31st December, then you may have completed a pro-rata amount of 4 hours CPD from 1st October to 31st December and then 11 hours from 1st January by 30th September 2019. This demonstrates that 15 hours, whether pro-rata or in full, have been completed by 30th September 2019.
It is also permitted for new employees to use any CPD undertaken at their previous workplace within the same 12-month period – if there are measures to verify the completion of such CPD hours. The minimum 15 hours are not in addition to the 35 hours already required for advisers to maintain their CII status, undertaking more hours embodies good practice.
In terms of the requirements of this training, there is no specific allocation of structured and unstructured training, this should be based on what a firm deems appropriate to ensure employees’ competence. The FCA states employees should possess ‘appropriate knowledge and ability in order to complete their tasks and perform duties adequately.’
Training must cover general insurance, life insurance and insurance-based investment products and knowledge should include:
So, however you have structured your CPD as a firm, everyone who has a material impact on the customer and who is involved in selling, or transacting on insurance contracts, will need to adhere to the IDD and will need to evidence the 15 hours of training.