FCA update on the Qualifications 48-month Rule

The FCA has published details of the action firms can take where employees are working towards a professional qualification subject to Training & Competence Rules and Guidance (specifically the 48-month Rule) and are impacted by exam cancellations due to the current Covid-19 crisis.

A reminder of the rule – If an employee carries an activity in FCA Handbook TC Appendix 1 (other than an overseeing activity), a firm must ensure that the employee attains an appropriate qualification within 48 months of starting to carry on that activity.

Covid-19 impacts – Qualification providers are cancelling exams because of coronavirus with no specific arrangements in place yet to reschedule them.

The FCA will extend 48 months by up to an additional 12 months in specific circumstances. The key points are:

  • For employees that have a set (registered/booked) examination date(s) which was cancelled or postponed by the examination provider or by the firm.
  • Cancellation by the firm – For example, because the employee is needed to carry out extra duties to manage risks, and/or to provide support, to consumers and businesses where it is not realistic to expect the employee also to fulfil the qualification requirement.
  • A time limit applies to this waiver. Firms may apply a time limit of up to 60 months where examinations were cancelled or postponed, up to and including 31 October 2020.
  • Firms will need to assess and decide if an extension should be granted to an employee and record the reasons for this.
  • Firms are still expected to ensure that employees have the skills, knowledge and expertise needed to discharge their responsibilities.

Please refer to the full communication included in FCA Coronavirus (Covid-19): Information for firms, accessed from the Firms tab on their website. Source and link below:


About Trailight:

Trailights PRM platform has been purposefully designed to meet a firms need to manage Training & Competence including professional qualification management i.e. assignment of appropriate qualifications, working towards progress tracking and capture of qualifications records. The platform fully supports the competence and capability assessment requirements for Fitness & Propriety.

At Trailight, we believe in transparency. Putting people risk and individual accountability at the heart of good governance is key to improving corporate culture around the world. For companies that want to improve their controls and the entire process of people management, Trailight’s solutions are built to create a framework that improves corporate culture and provides clarity.