Adviser CPD and the Statement of Professional Standing: the 35 hours, the 60-day rule and what the firm has to hold for each adviser

Most advisers think of CPD and the Statement of Professional Standing (SPS) as their own business: log the hours, renew with the institute, carry on. The rules in the FCA's Training and Competence sourcebook put the duty on the firm. A firm must ensure each retail investment adviser completes the hours, must get the SPS, must keep the records and must tell the FCA when something goes wrong. For a small advice firm that means one person needs to know, for every adviser, where the hours stand and when the SPS runs out.

This guide sets out what TC 2.1 requires, turns the hours into a monthly pace, and lists what the firm should hold on file. It covers retail investment advisers. A mortgage-only adviser does not need an SPS, though the firm still has to keep them competent.

The hours: 35 a year, 21 of them structured

TC 2.1.15R says a firm must ensure that a retail investment adviser "remains competent by completing a minimum of 35 hours of appropriate continuing professional development in each 12 month period". TC 2.1.16G adds that at least 21 of those hours should be structured. TC 2.1.20G gives examples of structured activity: courses, seminars, lectures, conferences, workshops, webinars and e-learning. Reading, research and informal learning count towards the rest.

Spread across a year, that is a small amount each month, which is why it slips:

The trouble is the catch-up. An adviser who has logged 15 hours after nine months has 20 hours left and three months to do them, which is 6 hours 40 minutes a month. If most of those 20 are structured, they need booked courses, not reading. A firm with three advisers owes 105 hours a year between them, 63 of them structured, and a quarterly look at the totals is enough to stop a late scramble.

TC 2.1.17R to 2.1.19G let a firm suspend the 35-hour requirement for an adviser on maternity, paternity or adoption leave, with long-term illness or disability, or with caring responsibilities. The firm decides, and it must record the dates and the reason.

The SPS: 60 days, then every year

TC 2.1.27R requires the firm to get independent verification from an accredited body that the adviser holds the right qualifications, has done the CPD and has made the annual declaration. TC 2.1.28R sets the timing: within 60 days of the adviser being assessed as competent, and annually after that. TC 2.1.29G says the verification should take the form of an SPS.

So an adviser the firm assesses as competent on 1 November 2026 needs a first SPS by 31 December 2026, and a new one before each one ends. The FCA's page for advisers says the SPS shows an end date no more than 12 months after verification, and it carries the adviser's reference number from the Financial Services Register.

The FCA's list of accredited bodies, last updated 19 February 2026, names three: the Chartered Institute for Securities and Investment, the Chartered Insurance Institute and Walbrook Institute London (formerly the London Institute of Banking and Finance). An adviser can only get an SPS from one of these. The FCA consulted in CP25/4 on removing two bodies from the list at their own request, so an adviser who renewed elsewhere in the past should check which body will issue the next one.

The annual declaration

TC 2.1.26R requires the firm to ensure each retail investment adviser confirms in writing every year that, in the previous 12 months, they complied with the conduct rules (APER or COCON) and completed the required CPD. The accredited body verifies this declaration as part of the SPS, but the rule sits with the firm, so keep a copy.

What the firm should hold for each adviser

TC 2.1.24R requires the firm to make and keep records of the CPD each retail investment adviser completed, and the dates of and reasons for any suspension. In practice a short file per adviser covers it:

1. The date the adviser was assessed as competent, and the 60-day deadline that followed.
2. The current SPS, its issuing body and its end date.
3. A CPD log with dates, hours, structured or unstructured, and what was learned.
4. The signed annual declaration for each year.
5. Any suspension of the CPD requirement, with dates and the reason.

Put the SPS end dates on the same calendar as the firm's other deadlines. Our guide on how long to keep client files covers retention for client records; training records are worth keeping on the same footing.

When something goes wrong

TC 2.1.31R requires the firm to notify the FCA as soon as reasonably practicable when a significant event happens in relation to a retail investment adviser, including when the firm stops treating them as competent or they fail to get a required qualification in time. A lapsed SPS or a missed year of CPD is a competence question the firm has to answer, not an administrative delay. If the person affected holds a senior management function, our guide on covering a senior manager under the 12-week rule explains the options. Training and competence is also a natural line in the Consumer Duty annual board report, where the directors can show they checked it.

Where Overlyft fits

An AI assistant set up by Overlyft can keep the tracker: each adviser's SPS end date, CPD hours against the monthly pace, and a reminder when someone falls behind or a renewal is two months away. It prepares the summary for whoever oversees competence in the firm. It does not decide whether an adviser is competent, approve a suspension or make a notification to the FCA. Those stay with the firm and its compliance function.