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SENTINEL

Compliance

Sentinel T&C.png

Training & Competence (T&C)

Training & Competence, 

The Beating Heart of a Strong Firm

Reduce Risk | Develop People | Retain Talent

What are the FCA's Training & Competence Requirements?

 
FCA-regulated firms must make sure that people carrying out regulated activities are competent, properly supervised, and remain competent over time.
 
For some roles, this is covered by the FCA’s specific Training and Competence rules, including qualification, supervision, CPD and record-keeping requirements. 

 

There is also a wider FCA expectation under the competent employees’ rule, which means firms must ensure that anyone involved in the regulated business has the skills, knowledge and expertise needed for their role.

 

In practice, good T&C should cover:

  • How you assess competence

  • How you evidence ongoing competence

  • T&C activities and the Consumer Duty

  • Supervision requirements — and their competence

  • Qualification requirements 

  • Continuing Professional Development 

  • Record keeping obligations

 
Most firms have a T&C scheme. Far fewer have one that is aligned to their firm and genuinely supports and evidences good client outcomes  

Talk to us about your T&C

When T&C Becomes a Paper Exercise

Many firms start with good intentions, but without defined structure and accountability, Training & Competence can easily become procedural rather than purposeful.

Weak T&C creates regulatory risk and cultural damage. It influences how advisers perceive their growth, leadership and future within the firm. They may not voice it — but they know when T&C lacks substance.

A frequent weakness in firms is treating Training & Competence as an extension of sales management. It isn’t.

T&C exists to ensure advisers have the knowledge, skill, expertise and professional conduct required to deliver suitable advice. When those foundations are not actively strengthened and evidenced, the advice process becomes exposed to unnecessary risk.

Under Consumer Duty, the stakes are higher still. Firms are now required to demonstrate - not just state - that their people deliver good outcomes for clients. A meaningful T&C framework is the clearest way to evidence that.

Where are you starting from?

Building a Scheme from Scratch

You’re a new or growing firm that needs a T&C framework in place; whether for an FCA authorisation application, a new adviser joining the team, or simply because you’ve outgrown operating without one. We design practical, scalable schemes built around your firm. Not a template. Not someone else’s scheme with your name on it.

Reviewing or Strengthening an Existing Scheme

Your T&C scheme exists , but you suspect it isn’t working as it should. Perhaps it was set up years ago and hasn’t kept pace with regulatory change, or file reviews have raised concerns. We carry out an independent review, identify the gaps, and help you rebuild with confidence.

Keeping Pace with Growth

Your team is growing, your business model is evolving, or new regulatory requirements have shifted the goalposts. A T&C scheme that worked three years ago may not be fit for purpose today. We help you adapt your framework so it remains robust, proportionate, and manageable.

What Sentinel Brings to Your T&C

At Sentinel, we help firms build T&C frameworks that do what they’re meant to do: identify risk early, develop advisers properly, and create an environment where good people want to stay.

 

Whether you’re improving an existing T&C framework, developing one for the first time, or considering an in-house Academy, we provide the structure needed to make it work in practice.

SMF Meeting between 2 people

What Good T&C Actually Looks Like

A strong scheme doesn’t have to be complicated — but it does need to be purposeful. These are the foundations:

Clear Competence Criteria

Well-defined standards for what competence looks like in each role, and a clear, documented point at which supervision levels can appropriately reduce.

A Structured Supervision Approach

Whether risk-based or trigger-based, supervision needs to be consistent, manageable, and properly documented. Good supervision develops people , it doesn’t just monitor them.

Meaningful KPIs

Not twenty metrics for the sake of it. Six to eight focused KPIs that reflect your business model and help you identify risk early — file review grades, CIP adherence, CPD completion, complaint patterns.

CPD — Evidenced and Linked to Development

The FCA requires advisers to complete 35 hours of CPD annually, of which 21 must be structured. CPD needs to be tracked, evidenced, and linked to individual development plans.

Record Keeping That Holds Up

From recruitment through to ongoing competence, the FCA expects comprehensive, accessible records. If you can’t evidence it, it didn’t happen.

Consumer Duty Alignment

Your T&C framework is your primary mechanism for demonstrating that your people understand and consistently deliver good client outcomes. It should be built with Consumer Duty front of mind.

How We Work With You

01

Understand

We start with your business, not a template. We talk through your firm’s structure, your advisers, your regulatory position, and where the pressure points are.

02

Review or Design

We either carry out an independent review of your existing T&C scheme — identifying gaps and areas of risk — or design a new framework from the ground up.

03

Embed

We help you put the framework into practice — working with your supervisors, supporting your team, and making sure the scheme is something your people can realistically maintain day-to-day.

04

Support

We don’t disappear once the framework is in place. Ongoing support is available to help you adapt to regulatory change and provide independent assurance where it’s needed.

How Sentinel Supports You

Build or Refine Your Framework

We help you design a T&C structure that is practical, scalable, and aligned to both adviser development and regulatory expectations.

Make It Work Day-to-Day

Too many schemes are over-engineered and impossible to manage.
We streamline processes so T&C becomes something your team can realistically maintain.

Connect T&C With Compliance

Your T&C framework should sit alongside your compliance monitoring. We help bring these parts together, strengthening oversight and accountability.

Support Your Supervisors

Supervisors are the engine room of any T&C scheme. We provide the training, guidance, and ongoing support they need to carry out their responsibilities with confidence, and to make supervision a genuinely developmental experience for advisers.

Oaklands Wealth Management Ltd - 

“Annabel’s support in understanding FCA requirements has been invaluable, particularly through tailored compliance visits and robust compliance monitoring plans. She consistently delivers clear, practical guidance and ensures our regulatory obligations are met with confidence and precision.”

SENTINEL

Compliance

FCA Compliance Consultants for UK Financial Services Firms

Registered address:

71-75 Shelton Street

Covent Garden

London

WC2H 9JQ

Company Name - Sentinel Compliance Consultants Limited

Company Number - 17049097

Telephone - 020 354 05049

Annabel - 07949 488 071

Speak to the experts today

We are more than compliance. 

Because strong firms don’t just recruit talent — they spot it and grow it

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