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The Insurance Distribution Directive states there is a "15-hour requirement ... as a minimum for anyone involved in ‘insurance distribution’" with regards to Continuous Personal Development.

I am a full-time software developer and an employee of an FCA-regulated Insurance Company. I work on Insurance websites, which we create for our clients to allow their customers to buy insurance products and to allow our clients maintain the policies they sell.

I was told I still have to complete 15 hours of CPD. Under the IDD, would I still be legally required?

Edit

We also take mandatory tests, most of which expire yearly, and time spent on this will count towards our 15 hours. These are tests such as GDPR, Data Protection, and Security, among others.

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    I have tagged this [UK] according to the link you posted. Feel free to change it if it's wrong. – nvoigt Dec 2 '19 at 12:10
  • @nvoigt Thank you, I hadn't known such tagging was the norm on this community, but does make sense. – Monstar Dec 2 '19 at 13:39
  • @JoeStrazzere I haven't discussed it much with them, though they would be reluctant to do it as well. I slightly discussed it with my manager but as the instruction came from above there isn't much he could say. – Monstar Dec 2 '19 at 13:39
  • @JoeStrazzere Sorry for the confusion, my manager's manager instructed those reporting directly to them to complete the 15 hours. I have since learnt the upper management have visibility on our progress and 'our' area of the business is the lowest. I thought there may have been a legal requirement for us to complete it and wasn't sure where this was stipulated. – Monstar Dec 2 '19 at 14:20
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Reading the site referenced by the OP under "What kind of staff are covered by the rules?" I see:

People in generic roles that are same for insurance and non-insurance companies are not covered by the rules. The FCA has listed some examples of these kind of roles, saying: ‘The requirements will not apply to employees in ancillary roles such as HR, facilities management and IT’.

...which suggests it's probably not a legal requirement. However, the bulleted lists of what can qualify as training subjects looks like a solid list of potential domain knowledge categories. For any project you're working on long term, understanding the business domain you're working in is valuable information that allows better understanding of the requirements you're given along with the ability to see when specifications are missing things that probably should be present. So I can understand an employer wanting to use training that they created for the legal requirement to help spread that knowledge beyond those people who're required by law to take it.

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    'IT' here probably means network/printer support (who really don't need the training) rather than the software developers implementing the rules behind the business, who really do. – Robin Bennett Dec 2 '19 at 12:28
  • I've edited my original question to state that we also do mandatory online tests, which should cover most of the legal aspects that could affect our company and clients. As annoying as I find them, I don't have any complaint doing these. I find 15 hours a rather lot of time, and I doubt the 15 hours will benefit me or my day-to-day tasks. – Monstar Dec 2 '19 at 13:44
  • I'm a developer and have been working for Life Insurance companies on an off for the last 7 years. The "CPD" that I've had has largely been around GDPR, Anti-Money laundering and other compliance related stuff. I've never taken "minimal training" (and who defines this exactly) for selling products, handling claims etc, but I agree with Dan Neely that this would be an excellent way to get domain knowledge. Someone else is paying you to become a better developer! Winner. – Justin Dec 2 '19 at 16:32
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Yes, this is a legal requirement. You are closely involved in the design of communication channels that customers base financial decisions on. Your employer is obligated to make you complete this training.

Given that you're in a more technical role and have little do do with the design of financial products, this may seem like a waste of your time. Consider that selling dubious financial products or deliberately misrepresenting important caveats of said products is a lot easier if your personnel is insufficiently familiar with the regulatory framework.

  • I find it difficult to disagree with your last line – Monstar Dec 2 '19 at 13:46
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    That last line was intended to be frivolous, sorry about that. UX and front-end devs whose work touches on copy and contents are often required to take the training. In my experience, if you only build html and CSS, you're technically not required to, but your employer will likely demand that you take the training anyway. If you could, potentially, correct a textual error or edit the contents of titles and paragraphs, such that the interpretation of their contents may change, then an auditor may conclude that you require that training. – TvZ Dec 6 '19 at 10:44

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