You are viewing TC 4 Specified modified requirements as of . TC 4 Specified modified requirements was last updated on 06/04/2026.

TC 4.1 Specified requirements for MiFID investment firms and for third country investment firms

06/04/2026R
  1. (1) For a firm in relation to its MiFID or equivalent third country business the rules set out in column 1 of the table in TC 4.1.4R below are amended as set out in column 2.
  2. (2) The amendments in (1) do not apply in relation to the provision of targeted support services where this would constitute MiFID or equivalent third country business.
03/01/2018R

In this section, references to relevant individuals are natural persons who, on behalf of the firm:

  1. (1)

    make personal recommendations to retail clients in relation to financial instruments; or

  2. (2)

    provide information to retail clients about financial instruments, investment services or ancillary services; or

who are otherwise responsible for the supervision of a relevant individual who has not acquired the necessary knowledge and competence to act in a capacity prescribed in (1) or (2).

23/10/2025R

References in TC 4.1.4R to a relevant individual’s knowledge and competence are to the knowledge and competence necessary to ensure that the firm, on behalf of which the relevant individual acts, is able to meet its obligations related to information to clients, and the assessment of suitability and appropriateness and reporting to clients under SYSC, COBS and PROD in relation to MiFID business.

  1. (1)

     [deleted]

  2. (2)

     [deleted]

01/01/2021R

Unless the context requires otherwise the rules in column 1 of the table are amended as set out in column 2:

Column 1Column 2
Relevant ruleAmendments
TC 2.1.1R(1)

Insert the following at the end of TC 2.1.1R(1):

“In addition, a firm must not assess a relevant individual as competent unless the firm has satisfied itself that the relevant individual possesses the knowledge and competence to enable the firm to meet its obligations under SYSC 5.1.5ABR. This means that the relevant individual has also:

(a) obtained appropriate experience which means that the relevant individual has successfully demonstrated the ability to carry on the activities through previous work experience. This work must have been performed, on a full-time equivalent basis, for a minimum period of 6 months; and

(b) attained an appropriate qualification which means a qualification or other test or training course that meets the criteria set out by the ESMA guidelines referred to in TC 1.1.1BG.

The level of knowledge and competence needed to fulfil the firm’s obligations reflects the scope and degree of the activities, as described in TC 4.1.2R above, carried out by the relevant individual.”

TC 2.1.2R

The provision is amended by adding after TC 2.1.2R:

“A relevant individual, who has not acquired the necessary knowledge or competence to carry out the activities in TC 4.1.2R above, cannot provide those activities under supervision for a period exceeding 48 months.”

TC 2.1.5R(1)

The provision is amended by adding after TC 2.1.5R:

“Where a relevant individual has not acquired the necessary knowledge and competence to carry out the activities described in TC 4.1.2R above:

(a) the firm must ensure that the individual supervising the relevant individual:

(i) has been assessed as competent to provide such personal recommendation or information;

(ii) has the necessary skills and resources to act as a competent supervisor; and

(iii) takes responsibility for the personal recommendation or information, referred to in TC 4.1.2R above, provided by the relevant individual under supervision as if the supervisor is providing the personal recommendation including any suitability report (COBS 9) or information; and

(b) the firm must ensure that the supervision provided to a relevant individual is tailored to the services provided by the individual.”

03/01/2018G

Rules in this section relate to the requirements in SYSC 5.1.5ABR.

03/01/2018G

For relevant individuals of an incoming EEA firm, with an establishment maintained by that firm (or its appointed representative) in the United Kingdom, the matters covered by SYSC 5.1.5ABR are matters reserved for the United Kingdom as the Host State regulator.

TC 4.2 Specified requirements for firms carrying on insurance distribution activities

06/04/2026R
  1. (1) For a firm, including a TP firm, which carries on insurance distribution activities the rules and guidance set out in column 1 of the table in TC 4.2.5R below are amended as set out in column 2.
  2. (2) The amendments in (1) do not apply in relation to the provision of targeted support services where this would constitute insurance distribution activity.

     

01/10/2018R

TC 4.2.1R is limited as set out in TC App 2 and TC App 3.

09/12/2025G
  1. (1) Firms are reminded that GEN 2.2 sets out how the Handbook applies to TP firms.
  2. (2) TC 4.2, to the extent that it applies (see TC 4.2.2R), including any amendments made after IP completion day (including for the avoidance of doubt new rules arising out of those amendments), continues to apply to TP firms.
09/12/2025R

In this section, non-investment insurance personnel are employees and other persons:

  1. (1)

     directly involved in the carrying on of the firm’s insurance distribution activities in relation to non-investment insurance contracts; or

  2. (2)

     within the management structure responsible for the firm’s insurance distribution activities in relation to non-investment insurance contracts; or

  3. (3)

     responsible for the supervision of a non-investment insurance employee (or other person) acting in the capacity as set out in (1).

09/12/2025G

In this section, and the provisions in column 1 of TC 4.2.5R, long-term insurance personnel are employees and other persons:

  1. (1) directly involved in the carrying on of the firm's insurance distribution activities in relation to: 
    1. (a) long-term insurance contracts (other than pure protection contracts);
    2. (b) long-term care insurance contracts; or
    3. (c) rights to or interests in a life policy;
  2. (2) within the management structure responsible for the firm's insurance distribution activities in relation to:
    1. (a) long-term insurance contracts (other than pure protection contracts);
    2. (b) long-term care insurance contracts; or
    3. (c) rights to or interests in a life policy; or
  3. (3) responsible for the supervision of a long-term insurance employee (or other person) acting in the capacity as set out in (1).
01/10/2018R

In TC 4.2 ‘employee’:

  1. (1)

    is not restricted to an individual working under a contract of employment; and

  2. (2)

    includes (without limitation) any natural or legal person whose services are placed at the disposal of the firm, under an arrangement between the firm and a third party; and

  3. (3)

    also includes appointed representatives and their employees.

09/12/2025R
Column 1Column 2
Relevant rules or guidanceAmendments either extending the scope, or adding and/or replacing rules and guidance in Column 1
TC 2.1.1R(1)

The provision is amended by adding after TC 2.1.1R(1):

‘A firm must ensure that a long-term insurance employee’s (or other person) appropriate knowledge and ability includes the requirements set out in SYSC 28.2.3R and is appropriate to the:

(a) role and activity carried out by the long-term insurance employee (or other person) within the firm; and

(b) type of distribution and the nature of the products sold.’

TC 2.1.15R; TC 2.1.17R; TC 2.1.24R and TC 2.1.25RThe rules apply as if references to retail investment advisers included ‘long-term insurance personnel’.
TC 2.1.15R(1)For firms whose long-term insurance personnel are not also retail investment advisers, the rule applies as if ‘35 hours’ was a reference to ‘15 hours’.
(2)

The rule is amended by adding at the end:

‘Where the long-term insurance employee (or other person) is also a retail investment adviser, the minimum 35 hours appropriate continued professional development requirement in TC 2.1.15R must include a minimum 15 hours covering the requirements in SYSC 28.2.3R.’

TC 2.1.16G 

For long-term insurance personnel acting in that capacity, the guidance is replaced by the following:

‘To meet the requirements in TC 2.1.15R (as modified by TC 4.2.5R) a long-term insurance employee’s (or other person) continued training and development can encompass various types of facilitated learning opportunities including courses, e-learning and mentoring.’

TC 2.1.18G, TC 2.1.19G, and TC 2.1.23G The guidance applies as if references to retail investment advisers included ‘long-term insurance personnel’.
TC 2.1.24R 

The rule is amended by adding after TC 2.1.24R(2):

‘the firm must be in a position to make available to the FCA, on request, the name of the person responsible for this record keeping requirement.’

TC 3.1.1R 

The provision is amended by adding after TC 3.1.1R(3):

‘a firm must keep an up-to-date record of the continued professional training or development completed by each long-term insurance employee (or other person) in each 12 month period,

 (a)for not less than 3 years after the long-term insurance (or other person) stops carrying out the activity; and
 (b)the firm must be in a position to provide any version of the record to the FCA on request.’
09/12/2025R

Where the long-term insurance employee (or other person) is also a retail investment adviser the rules and guidance in TC 4.2.5R apply as follows (unless otherwise stated in TC 4.2.5R):

  1. (1)

     the unamended TC rules and guidance in column 1 of TC 4.2.5R apply in relation to the person when acting in the capacity of a retail investment adviser; and

  2. (2)

     the amended TC rules and guidance in column 2 apply in relation to the person when acting in the capacity of a long-term insurance employee (or other person).

09/12/2025R

Where a non-investment insurance employee (or other person) is also a retail investment adviser:

  1. (1) the unamended TCrules and guidance in column 1 of TC 4.2.5R apply in relation to the person when acting in the capacity of a retail investment adviser; and
  2. (2) the applicable rules and guidance in SYSC 28 apply in relation to the person when acting in the capacity of a non-investment insurance employee.
09/12/2025G

Where a non-investment insurance employee (or other person) is also a retail investment adviser:

  1. (1) the firm should take into account the elements of professional knowledge and competence listed in SYSC 28.2.2AG, in light of the role and activity carried out by the individual within the firm when determining the appropriate continued professional development required for the purposes of TC 2.1.15R; and
  2. (2) the guidance in TC 2.1.16G is replaced with the following guidance: ‘To meet the requirements in TC 2.1.15R, a non-investment insurance employee’s continued training and development can encompass various types of facilitated learning opportunities including courses, e-learning and mentoring.’
09/12/2025G

Rules and guidance in this section relate to SYSC 28 (Knowledge and competence for carrying out insurance distribution activities).