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CII ends gap-filling for advisers

News item

Publication date:

08 February 2021

Last updated:

17 February 2021


Policy and Public Affairs

When the Retail Distribution Review requirements were introduced in 2012, the FCA allowed advisers to use existing Level 4 qualifications and for any gaps in the content between existing and new exams to be filled with Continuing Professional Development.


Up until now the CII has awarded a Statement of Professional Standing to individuals who had a qualification close to the FCA’s requirement for investment advisers provided they went through the gap-fill CPD process established during the RDR.

A CII review found the qualifications allowed under gap-fill are beginning to be outdated so the professional body has decided it is now in the interests of consumers to end this option.

Why has the CII decided to end gap fill?

The gap-filling option enabled a fair transition to Retail Distribution Review qualification requirements for advisers who had, for example, been continuously absent from work.

However, given the length of time that has elapsed since the introduction of the Retail Distribution Review it is now appropriate to end this transitional approach and apply appropriate standards of recognition of prior learning to professionals who have qualifications that do not fully meet the FCA’s criteria for advising on retail investment products.

How do I know if my qualification needs gap fill?

The FCA Handbook has a complete list of qualifications that require gap fill at:

The CII qualifications that require gap fill to attain an SPS are:

  • Fellow or Associate (life and pensions route only)
  • Advanced Financial Planning Certificate
  • Diploma in Financial Planning
  • Fellow (FCII) (where candidates hold appropriate life and pensions modules)
  • Fellow (FLIA Dip)
  • Advanced Diploma in Financial Planning
  • Associate (ACII) (where candidate holds appropriate life and pension modules)
  • Associate (ALIA Dip)

How do I apply for an SPS with gap-fill?

If you have any questions about applying for an SPS with gap fill, contact our customer services team on

What happens if I don’t apply for an SPS with gap-fill by 31st August 2021?

If you do not apply for an SPS with gap-fill by 31st August 2021 and you have not had an SPS before, you will have to complete an RDR compliant qualification in order to attain an SPS.

When is the last time I can sit an exam to complete the Diploma in Financial Planning and apply for gap fill?

The last examination that you can sit to attain the Diploma in Financial Planning and apply for gap-fill is July 2021. A full list of exam sitting dates is at

I have had an SPS in the past, which I achieved through the Diploma in Financial Planning and Gap Filling. However, in my current role I no longer require an SPS. If I want to apply for an SPS in future, will I need to do new qualifications?

No, you will not need to complete new qualifications. Gap-filling was a transitional measure for RDR, and those who have completed this transitional measure and attained an SPS before August 31st 2021 will be ‘grandfathered’ into the new system.

I have never had an SPS, but I do have the Diploma in Financial Planning. If I do my gap filling between now and August 31st, can I apply for an SPS at some point after 31st August 2021 without doing new qualifications?

No, if you have never had an SPS and have not applied for an SPS before 31st August 2021, you must complete an RDR-compliant qualification. We have taken this decision because allowing members to ‘lodge’ the continuous professional development necessary to complete the gap fill requirements before 31st August 2021 would create two groups of people – those who had completed gap-fill and could ‘activate’ their right to apply for an SPS at any time, and those who may have done more up-to-date CPD but who were not allowed to apply for an SPS with gap-fill. As a result, extending ‘grandfathering’ to people who could ‘lodge’ gap-fill CPD would perpetuate confusion around gap-filling, potentially for decades to come, and foster a sense of unfairness among those who had not ‘lodged’ their CPD before the August 31st 2021 deadline.

I will complete my gap filling by August 31st, but I have never had an SPS before, and I am not sure that the FCA will give me and Individual Registration Number (IRN) by August 31st. I can’t apply for an SPS without an IRN, so am I going to have to do new qualifications if I miss the August 31st deadline?

We understand that some people will have difficulty applying for an SPS before August 31st 2021, even though they have already completed their qualifications and gap-fill. This is because they may not have received an IRN from the FCA in the past, and are waiting for an IRN from the FCA as part of the certification process.

If you are in this situation, please contact us at You must contact us before 31st August 2021.

Do all the accredited bodies have the same approach to gap-fill?

Each accredited body must take its own approach to gap-fill. Please check with the relevant accredited body to verify its approach.

This document is believed to be accurate but is not intended as a basis of knowledge upon which advice can be given. Neither the author (personal or corporate), the CII group, local institute or Society, or any of the officers or employees of those organisations accept any responsibility for any loss occasioned to any person acting or refraining from action as a result of the data or opinions included in this material. Opinions expressed are those of the author or authors and not necessarily those of the CII group, local institutes, or Societies.