RE5 training for staff: an employer's guide (2026)

If your firm brings on representatives who give financial advice, the RE5 is not optional and the clock starts the day they are appointed. This guide explains what the law expects of you as an employer, what a missed deadline actually costs, and how to choose RE5 training for your staff without wasting a training budget on the wrong format.

What the law expects: the 24-month DOFA rule

Under the FAIS regime, a person who is appointed as a representative to give advice or render intermediary services must pass the relevant regulatory exam (the RE5 for representatives) within a set window of being appointed. That window runs from the representative’s date of first appointment (DOFA), and it is currently 24 months. Until a rep has passed, they can only operate under supervision, and if the deadline passes without a pass, they can no longer act as a representative for those products.

The practical consequence for an employer is simple: every rep you hire arrives with a personal countdown, and it is your responsibility to make sure they are ready in time. Requirements and transitional arrangements do change, so treat this article as orientation and confirm the current rules for your specific reps with the FSCA and Moonstone. For a plain-English walk-through of the exam itself, see our RE5 exam guides.

The real cost of a missed deadline

It is tempting to treat the RE5 as the employee’s problem. It isn’t. When a rep does not pass in time, the cost lands on the firm:

• Lost productivity. A rep who can no longer give advice cannot generate the revenue you hired them for, and any supervision arrangement you relied on falls away.
• Re-hiring and re-training. Replacing a rep who washed out on the exam means starting the DOFA clock again with someone new, and paying to train them too.
• Debarment and register risk. Keeping someone on as a representative when they no longer meet the competence requirements is a compliance problem you have to explain, and it can put the individual at risk of debarment.

None of this is a reason to panic-buy the most expensive training you can find. It is a reason to make the preparation visible and measurable, so a rep who is drifting off track is obvious months before the deadline rather than the week before.

Your competence-register duties

As an FSP you are required to keep a register of your representatives and to maintain evidence that they meet the fit-and-proper requirements, which include the relevant regulatory exam. In practice that means you should be able to show, for any rep and at any time, whether they have passed the RE5, and if not, that they are within their window and being supervised. If you have more than a handful of reps, doing this in a spreadsheet you update by hand is where things quietly go wrong.

The compliance side of this (supervision, deadline tracking and keeping the file audit-ready) deserves its own treatment. If that is your job, read the companion piece: the FSP compliance officer’s guide to getting reps exam-ready.

Workshops vs self-paced online training

RE5 training for employees broadly comes in two shapes. Both can work; they suit different firms and different reps.

In-person or live workshops

A facilitator takes a group through the material over one or more days, often ending in a mock. The upside is structure and a fixed date in the diary. The downsides are cost and rigidity: you pay per head (plus travel and venue), reps are off the floor for the duration, and everyone moves at the same pace regardless of who already knows the material and who is struggling. A workshop also tends to be a one-off event; useful for a push, weak for the weeks of spaced practice that actually move a score.

Self-paced online training

Reps work through the material in their own time, ideally with practice that adapts to their weak areas. The upside is flexibility, lower per-seat cost, and preparation that fits around client work. The risk with self-paced training is that it can become “here is everything, good luck”, so the thing that matters most is whether you, the employer, can see progress. Self-paced only beats a workshop if you can tell who is on track and who is not.

What to look for in tracking and reporting

Whatever format you choose, the reporting is what protects you. Before you buy, ask whether the tool can show you:

1. Readiness against the real pass mark for each rep, not just how many hours they have logged. Time spent is not the same as being ready.
2. Per-topic strengths and gaps, so a struggling rep can be pointed at the exact areas letting them down.
3. Activity: who has started, who is studying regularly, and who has gone quiet.
4. Deadline visibility: a countdown to each rep’s DOFA or exam date, with a clear flag when someone is behind the pace they need.
5. An export for your compliance file: ideally a CSV you can drop straight into your competence-register evidence.

One caution on privacy: a good tool shows you readiness and aggregates, not a rep’s individual answers to individual questions. You need to manage competence, not surveil people.

A sensible way to compare cost

Do not compare sticker prices; compare the total cost of getting a rep genuinely ready. A fair like-for-like adds up:

• the per-seat or per-head price of the training itself;
• travel, venue and any facilitator costs for in-person options;
• the floor time reps lose while training (a day in a workshop is a day not with clients);
• the cost of a re-sit, or worse a missed deadline, if the format didn’t actually prepare them.

Framed that way, a lower-priced self-paced seat that keeps reps working and shows you their readiness often compares well against a premium workshop, provided it comes with the reporting above. Run the numbers for your own firm rather than trusting a headline figure from anyone (including us).

How PassPath fits

PassPath is an independent, self-paced RE5 and RE1 prep tool. Each rep gets a personal study path built from a short readiness check, then adaptive practice that targets their weak topics. On the employer side you get a live dashboard: readiness per rep against the real pass mark, per-topic mastery, activity, a deadline countdown with at-risk flags, and a CSV export for your compliance file. Seats are a one-time payment for 180 days each, bought by card and assigned when you invite someone, and an unstarted seat can be reassigned if a rep leaves before they begin.

If you want to see how team seats, pricing and the dashboard work, head to PassPath for teams. If you just want to understand where a single rep stands today, the free readiness check below is the fastest honest starting point.