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Gap fill no longer available from 1 December 2019



As part of the FCA’s Retail Distribution Review (RDR) in 2010, the examination standards for retail investment advisers required extension and examining at a higher level than was previously required.

In the early stages of RDR implementation these changes were not fully defined but the FCA was aware that there was a limited amount of time for existing advisers to demonstrate competence against the new standards. In order not to delay those who wanted to update their qualification ahead of the implementation timeline (31 December 2012), the FCA agreed advisers could study the newly recognised, fully RDR compliant Level 4 (or above) qualifications that were in place or rely on what became known as “transitional qualifications”.

Once the new standards were in place, individuals would then need to carry out “top up” continuing professional development (CPD) to cover gaps between those transitional qualifications and the new standards. This became known as “gap fill”.


Changes and rationale

The FCA required that practising advisers completed any gap filling activities by 31 December 2012, if they wanted to continue giving advice into 2013 and beyond.  After December 2012, any new advisers needing an Appropriate Qualification for giving retail investment advice were required to hold a fully RDR compliant qualification.  Alternatively, if the adviser held a transitional qualification, they could follow the appropriate gap fill route.

It is now six years since the deadline for practising advisers to complete gap fill has passed and the FCA has subsequently re-explored and revised the examination standards required for retail investment advice.  Changes have been recommended which no longer make it appropriate to consider “gap filling” as a suitable option to obtain an RDR compliant qualification. Therefore, CFA UK will no longer be offering gap fill as a route to obtain an Appropriate Qualification from 1 December 2019.


How will the changes affect CFA UK members: IMC and ASIP holders

It may be that you had not considered gap filling, previously, if you had no reason or regulatory requirement to meet the standards for giving retail investment advice. CFA UK currently offers gap fill routes for those who hold the Level 3 Investment Management Certificate (IMC) and also for ASIP holders (who passed the IIMR Associate Examinations – ASIP by examination).

However, from 1 December 2019, this will no longer be the case and CFA UK will not offer any gap fill from that date. If you have already registered with us to complete gap fill prior to 1 December 2019, there will be a three- month window, post 1 December 2019, to enable you to complete your gap fill, up to 28 February 2020, at the latest. We will unable to accept any new gap fill requests or bookings from 1 December 2019 onwards. 

If you wish to complete the CFA UK gap fill programme, please contact us at