The Evidence Gap: Why T&C Management Breaks as Your Firm Grows

Managing Training & Competence is straightforward when your firm is small. A spreadsheet, a folder of records, a handful of supervisory relationships. It works — until it doesn't.

As adviser numbers grow, so does the admin. More CPD to track, more competence sign-offs to evidence, more observations to document. And in an environment where the FCA expects ongoing, audit-ready evidence of competence — not just completion certificates — that gap becomes a regulatory risk.

This guide is for compliance, training and quality, HR and senior management teams at financial services firms who want a clearer picture of where T&C management typically breaks down, what the regulator now expects to see, and what a scalable system should do to close the evidence gap.

In this guide, we explore:

• Why T&C admin compounds as firms grow — and the five breaking points that create regulatory exposure.
• What the FCA's focus on outcomes-based supervision means for T&C evidence.
• What a flexible, configurable T&C system should look like in practice.