FAIS CPD: planning the cycle that closes on 31 May

Contents

1. The cycle, and why the date is awkward
2. How many hours each person owes
3. What counts, and what does not
4. Who is out of scope, and who starts late
5. The competence register is the deliverable
6. A rhythm that survives renewal season
7. Frequently asked questions

The continuous professional development cycle now running opened on 1 June 2026 and closes on 31 May 2027. Read in September, that is a quarter of it gone — and in most brokerages of three to fifty people, nobody has logged an hour yet. In September that is fine. In April it is a problem, because the same three people who run renewals, claims and the WhatsApp inbox will each need up to eighteen accredited hours inside eight weeks, in the middle of the busiest quarter of the year.

This is a planning guide rather than a training catalogue: what Chapter 4 of the fit and proper Determination asks of an FSP, its key individuals and its representatives, who is in scope and who is not, and a rhythm that turns 31 May into a formality.

The cycle, and why the date is awkward

CPD sits in Chapter 4 of the Determination of Fit and Proper Requirements for Financial Services Providers, 2017 — Board Notice 194 of 2017 — made under the FAIS Act and supervised by the FSCA. A CPD cycle is defined there as a period of twelve months commencing on 1 June of every year and ending on 31 May of the following year. The obligation itself is older than most people assume: it was first introduced in Board Notice 106 of 2008 and only came into effect on 1 June 2018, which is why advisers with twenty years in the industry still treat it as a new rule.

The cycle is fixed, and it is aligned to nothing else in a brokerage calendar — not the financial year, not the FSP annual compliance report, not the insurers' renewal seasons. That misalignment is the practical reason CPD gets missed. Nothing in the ordinary run of the year reminds you it exists until the deadline is close enough to hurt.

How many hours each person owes

The number is driven by the classes and subclasses of business a person renders financial services in, not by seniority or job title. FSCA Communication 2 of 2019 sets out the three tiers with worked examples:

Scope of financial services rendered	Example	Minimum per cycle
A single subclass within a single class of business	Personal Lines: Motor only	6 hours
More than one subclass within a single class of business	Personal Lines: Motor and Personal Lines: Liability	12 hours
More than one class of business	Short-term Personal Lines, Long-term Insurance and Investments	18 hours

Read that table against your register of representatives, licence line by licence line, rather than against what people do day to day. Two things usually surface. The principal and the key individual are almost always on eighteen hours, because their authorisations are the widest in the firm. And the administrator who "only does funeral" may owe nothing at all — for the reason set out in the next section.

What counts, and what does not

A CPD activity must be accredited by a professional body recognised by SAQA and allocated an hour value by that body, it must be verifiable, and it must be relevant and appropriate to the person's actual role and function. Around that core, the boundaries are sharper than most brokerages assume:

• Product-specific training does not count. The insurer's Tuesday morning session on a new commercial wording is training you should be doing, and it belongs in your competence register — but not as CPD hours.
• Work towards a qualification does not count, and neither do the regulatory examinations. Passing the RE5 is a competence requirement in its own right, never a substitute for CPD hours.
• Class of business training can be recognised, provided the activity meets the relevance and accreditation requirements of the Determination. That surprises people, because class of business and product-specific training often arrive in the same brochure from the same provider.
• Foreign professional body activities can be recognised. FSCA FAIS Notice 35 of 2019 allows activities recognised and given an hour value by a foreign professional body — a CFA charterholder's hours, for instance — to be counted. The FSCA is explicit that this exempts nobody from CPD; it only widens what may be counted towards it.
• A professional body's hours are not automatically your hours. If your body requires thirty hours a year and only ten of them are relevant and appropriate to your role as a representative, ten is the number that counts for fit and proper purposes.

Who is out of scope, and who starts late

Three dispensations matter disproportionately to a small brokerage, and all three are worth confirming in writing before you buy training:

1. Tier 2 products only. A representative appointed to render financial services in respect of Tier 2 products only is not required to comply with the CPD requirements. For a funeral-led book that is a genuine saving — and a trap, because the day that person is appointed for a Tier 1 product again, they must first comply with CPD.
2. Representatives under supervision. CPD applies to a supervised representative only once they have met the qualification, regulatory examination and class of business training requirements, or once the period allowed to meet them has expired, whichever comes first. If you are onboarding an adviser under supervision, the cycle they join is usually not their first CPD cycle.
3. Interrupted employment. Where a representative was continuously absent from work for the reasons the Determination lists, the FSP must calculate reduced hours for that cycle using the calculation set out there. Maternity leave and long illness are not silent write-offs: somebody has to do the arithmetic and keep it on file.

The competence register is the deliverable

Hours completed and not recorded are, from a supervisory point of view, hours not completed. The FSP must establish, maintain and regularly update a competence register recording qualifications, completed regulatory examinations, product-specific training, class of business training and CPD for the FSP, its key individuals and its representatives. CPD activities must be recorded in that register within thirty days after the expiry of the cycle — so 30 June, not "sometime in the winter".

The FSCA has not yet prescribed the form, manner and intervals for submitting the register, which means firms keep it and produce it on request. In practice the request arrives attached to an inspection or a complaint, and the answer is due in days. One row per activity per person — the activity, the accrediting body, the hour value, the date, the certificate reference — is enough. A folder of certificates nobody has ever added up is not. The same test applies to your client conversation records: the duty is not only to hold them, but to retrieve them within a reasonable time.

A rhythm that survives renewal season

1. June — set the numbers. One line per authorised person: hours owed, dispensations claimed, and the reason. Half an hour of work that removes every argument later in the cycle.
2. September — first checkpoint. Book the accredited sessions for the whole cycle now, while the diary is still theoretical. Aim for a third of the hours banked by the end of the month.
3. December — two thirds done before the shutdown. January and February disappear into new business and motor claims; assume they will contribute nothing.
4. March — the last honest window. Anything not booked by the end of March will be done badly, or not at all, in the fortnight before 31 May.
5. June again — record within thirty days. Update the competence register, file the certificates against each row, and set next year's numbers in the same sitting.

CPD slips in a broker's diary for a structural reason rather than an attitudinal one: client work is interrupt-driven and CPD is not, so the inbox always wins. A brokerage that runs client conversations in a shared inbox rather than on individual phones — with AI-drafted replies waiting for a human to approve them, and routine questions answered under rules with escalation when the tone turns — buys back exactly the kind of uninterrupted afternoon a two-hour accredited session needs. That is where a system such as ORIS helps: it holds the conversations, the customer record and the follow-up, and exports to CSV for your compliance file. It does not hold your competence register. That stays with the FSP, and so does the responsibility.

Frequently asked questions

Do unused CPD hours carry over to the next cycle?

Plan on the basis that they do not. The Determination frames the requirement as a minimum number of hours per cycle, and the FSCA has previously confirmed that hours completed during an extension period could not be counted towards the following cycle. Treat every 1 June as a reset and build the hours inside the cycle they belong to.

What happens if someone misses the deadline?

Non-compliance with a competence requirement is non-compliance by the FSP, not just by the individual, and it can attract regulatory action. The practical consequence usually comes first: a representative who does not meet the requirements should not be rendering financial services for those products, which is an operational problem for a firm of five people in the middle of renewals.

Does the key individual have to do CPD as well?

Yes. The requirement applies to the FSP, its key individuals and its representatives, and the hours are calculated the same way, on the classes and subclasses of business concerned. Key individuals in small firms usually carry the widest authorisations, which puts most of them in the eighteen-hour band.

Can webinars and recorded sessions count?

The format is not the test. What matters is that the activity was accredited by a SAQA-recognised professional body and given an hour value, that it is verifiable, and that it is relevant and appropriate to the person's role. Ask the provider for the accreditation and hour value before you book, not after the session.

Where should the register live?

Anywhere you can produce it quickly and prove it was maintained over time — a spreadsheet in your compliance file is perfectly acceptable. What matters is that it is updated within thirty days after the cycle closes, that certificates are filed against each entry, and that one named person in the firm owns it.