How to establish a training and competence (T&C) scheme

To meet Financial Conduct Authority (FCA) requirements, you must create a formal Training and Competence (T&C) scheme that documents how you assess, supervise, and maintain the professional skills of everyone in your firm. This framework is not just a "nice-to-have"; it is a mandatory tool used to prove to the regulator that your business provides high-quality advice and protects its customers from incompetent service.

What is a T&C Scheme?

A T&C scheme is a written policy that outlines the journey of an individual from their first day at your firm to becoming a fully "competent" practitioner. It doesn't just apply to new staff; even if you are a sole trader, you must have a plan for how you will maintain your own high standards and stay up-to-date with changing regulations.

Core Components of Your T&C Scheme

Your document should be structured logically. Most successful schemes are broken down into the following four stages:

1. Assessing Initial Competence: Describe how you verify that someone is fit for the job. This includes checking qualifications, previous experience, and conducting initial assessments before they are allowed to give advice unsupervised.
2. Attaining Competence: Outline the "training" phase. If you hire someone who isn't yet fully qualified or experienced in your specific niche, how will they be supervised? What milestones must they hit to be signed off as competent?
3. Maintaining Competence: This is the ongoing phase. You must detail how you ensure staff stay sharp. This is primarily done through Continuing Professional Development (CPD). For most regulated roles, this means a minimum of 35 hours of relevant learning per year.
4. Supervision and Monitoring: Detail how you will monitor performance. This often involves regular one-to-one meetings, "observations" (watching an adviser in a client meeting), and file reviews (checking that the advice given was documented correctly and was suitable for the client).

How to Draft Your Scheme

You don't need a 100-page manual, but your scheme must be robust. Follow these steps to build it:

Section	What to Include
Roles & Responsibilities	Identify who is responsible for the T&C scheme (usually the person in the SMF16 Compliance role) and who acts as the "supervisor."
Key Performance Indicators (KPIs)	List the metrics you will use to measure competence, such as complaint rates, file review scores, and CPD completion.
The Supervision Cycle	State how often supervision happens (e.g., quarterly one-to-ones, monthly file audits).
Record Keeping	Explain where records of training, CPD, and assessments are stored. The FCA expects these to be available for inspection at any time.

Tips for Success

Keep it Proportional: If you are a very small firm, your T&C scheme should be simple and manageable. Don't commit to a level of supervision or reporting that you realistically won't have the time to complete.

Remember, the FCA's Consumer Duty places a heavy emphasis on "good outcomes." Your T&C scheme is your primary evidence that your team has the skills necessary to deliver those outcomes. Ensure you review the scheme at least once a year to make sure it still fits your business model and any new regulatory updates.