On 20 April 2020, the FCA updated its COVID-19 web page providing further information on how firms can comply with requirements to ensure that their employees complete appropriate qualifications during the COVID-19 pandemic.

The web page explains:

  • during the pandemic, the FCA still requires firms to ensure that all employees have the skills, knowledge and expertise needed to discharge their responsibilities. However, it has no intention of taking action against a firm or accountable individual that is not able to ensure that an employee has attained an appropriate qualification within the required 48 months (TC 2.2A.1R) because the relevant examinations were cancelled or postponed;
  • in such circumstances the FCA will treat the time limit for attaining the appropriate qualification as ‘within 48 months or, where necessary, as soon as reasonably practicable afterwards, up to a further 12 months’ instead of ‘within 48 months’. Affected employees of the firm will, if needed, have an additional 12 months to complete the appropriate qualifications. Firms will need to assess and decide if an extension should be granted to an employee and record the reasons for this;
  • a firm’s affected employees include those employees that have a set (registered/booked) examination date(s) which was cancelled or postponed by the examination provider or 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 during these challenging times, and where it is not realistic to expect the employee also to fulfil the qualification requirement; and
  • the FCA will adopt this approach for 6 months, until 31 October 2020. This means that firms may apply a time limit of up to 60 months where examinations were cancelled or postponed, up to and including 31 October 2020.