MiFID Training: Maintain and Evidence Staff Competence

The reviewed ESMA knowledge and competence guidelines do not prescribe a universal annual 15-hour figure. They include at least an annual review of development and experience needs. The training plan must reflect the role, products and applicable national requirements. A rule from another regulated activity should not be transferred without checking its scope. We document the basis assessed for the relevant roles and the resulting learning plan.

We start with actual activities: who advises clients, who provides product information and who performs other securities business tasks? The role matrix identifies required knowledge, existing evidence and responsible managers. Compliance staff and managers receive separately agreed learning objectives. A single course for everyone can miss important differences in responsibilities.

We compare roles and products with current materials and observed problems. A module might address explaining costs, handling incomplete client information or recording an advisory decision. Each practical case has a learning objective and assessment guide for the firm to approve. Outdated product examples and obsolete process instructions are identified for revision.

The register connects the staff role, module version, attendance, assessment date, outcome and follow-up action. Existing qualifications and experience are linked to their supporting records. Gaps remain open until agreed criteria are met. Access and retention arrangements are agreed with the responsible teams. An attendance certificate is not presented as complete proof of competence or regulatory acceptance.

Suitable findings become specific learning objectives. Repeated omissions in advisory records can be addressed through exercises using anonymised cases, followed by an agreed reassessment. If the problem persists, unclear instructions, system constraints and resource gaps should also be examined. More training is not the answer to every control failure.

An assigned owner assesses the roles and modules affected by each change. The change record identifies the checked source, the firm’s interpretation, the planned use date and the amendments needed. Learning needs for new products are considered before their use in the relevant distribution process. Updates are tied to verified requirements for the engagement rather than speculative reform claims.

We request role descriptions, a product overview, current training materials, sample records and relevant control findings. Together we select a pilot area and agree scope, access and acceptance criteria. The deliverable is an operational training and evidence process. It does not replace a comprehensive control review, independent internal audit or statutory examination.

We first examine whether the current system can record role assignments, module versions, assessments and follow-up status. Where it can, the project can work within that system. A representative record is checked from assignment through completion and export. A platform migration or new software purchase is only a separately scoped option when a demonstrated requirement cannot be met.

Exercises use realistic decision points from the agreed advisory process. Participants explain their reasoning and receive feedback against the assessment guide. Managers can then review selected work examples within the agreed scope. The comparison helps distinguish a knowledge gap from a process or system problem; it does not turn a small sample into a firm-wide compliance conclusion.

Useful measures include overdue assignments, unresolved assessment gaps, time to follow-up and reassessment outcomes. Each measure needs a defined population, owner and data source. Attendance rates and practical assessment results are shown separately. Targets are agreed for the actual process rather than presented as universal benchmarks or promised reductions in regulatory incidents.

We map the points where staff provide information, explain a product or support a client decision in each channel. Case exercises can then use the relevant screen flow, conversation or handover. Common learning objectives can be reused while channel-specific steps remain explicit. Testing the entire digital service or its algorithms is outside this training assignment unless separately agreed.

Delivery can combine facilitated remote sessions, individual preparation and supervised practical exercises. The format must allow questions and meaningful assessment of the agreed learning objectives. We check access, language needs and recording arrangements before the pilot. Remote attendance is recorded as participation, with assessment outcomes and unresolved questions documented separately.

We establish a shared set of learning objectives and identify the jurisdictions, products and roles that require local review. Country-specific differences are recorded and reviewed by the responsible specialists before materials are used. Translated terminology and examples receive a consistency check. An English course is not assumed to satisfy every national competence requirement.

Automation can help assign modules, identify overdue actions and prepare reports from validated records. AI-generated exercises require subject-matter review before use, and sensitive client or staff data should not be entered into unapproved tools. Assessment decisions retain an accountable owner. We make no unsupported promises about predictive accuracy, learning gains or automatic regulatory compliance.

The handover includes the role matrix, approved module inventory, assessment guides, evidence register, open actions and update responsibilities. The team walks through a sample assignment and reassessment so the operating procedure can be repeated. Remaining dependencies are recorded. Ongoing content maintenance, platform support and independent assurance are separately scoped.