What belongs in a representative competence register (and how to keep it current)

The competence register is one of those FAIS obligations that is simple in principle and painful in practice. This guide sets out what a representative competence register should contain, how to keep it current without a year-end scramble, and how to evidence RE5 readiness before the exam is passed.

What is a competence register, and why does it matter?

Under the FAIS Act, an FSP must maintain evidence that every representative meets the fit-and-proper requirements for the financial products and services they are authorised to advise on. The competence register is where that evidence is recorded and kept current. It is not a nice-to-have: it is the document a supervisor, an auditor or the FSCA can ask to see, and the thing that shows you have been managing competence rather than assuming it.

The register sits at the intersection of two duties. First, appointing and keeping representatives who are genuinely competent. Second, being able to show it on request. A register that is tidy but a year out of date fails the second duty; a register that looks complete but was never checked against reality fails the first.

What must the register contain for each representative?

Requirements are updated over time, so treat the list below as a practical starting point and confirm the current detail with the FSCA. For each representative, a workable register records:

• Identity and role: full name, ID, date of first appointment (DOFA), and the product and service categories they are authorised for.
• Fit-and-proper status: honesty and integrity, and any debarment history.
• Qualifications: the recognised qualification for their role, with dates.
• Regulatory examinations: the RE5 for representatives or RE1 for key individuals, with the deadline until it is passed and the pass date once achieved.
• Class of business and product training: completed product and class-of-business training relevant to their categories.
• Supervision: whether the representative works under supervision, by whom, and the arrangements.
• Continuous professional development: CPD hours logged against the current cycle.
• Review trail: the dates you last reviewed the representative and any actions you took.

The single most useful field is often the least glamorous: the DOFA date. Everything about the regulatory-exam deadline keys off it, so if it is wrong or missing, every deadline you calculate downstream is wrong too.

How do you keep the register current?

A register goes stale the moment it becomes a once-a-year exercise. The firms that keep theirs audit-ready treat it as a living document with a fixed rhythm:

1. Assign an owner. A register nobody owns is a register that quietly rots. One named person should be accountable for it.
2. Review on a cadence. A short monthly pass beats a frantic annual scramble. Sort by deadline, look at who is inside their window and not yet through their exam, and record that you looked.
3. Update on events. A new appointment, a passed exam, a change of product categories, or a move onto or off supervision: each is a trigger to update the register that week, not at year end.
4. Keep the evidence attached. A date in a spreadsheet is a claim; the certificate, the CPD record and the dated review note are the evidence. Store them where you can produce them in minutes.

The test of a good register is simple: if an auditor asked for proof that a specific representative was competent for a specific product category on a specific date, could you produce it without a week of reconstruction? If yes, your register is doing its job.

What evidence proves RE5 readiness before the exam is passed?

The exam result is binary and it arrives late. Between appointment and that result, the honest answer to “is this representative on track?” is often a shrug. That gap is where deadlines quietly turn into debarment risk.

You cannot record a pass that has not happened, and you should never imply one. What you can record is a defensible readiness signal: evidence that the representative is preparing, where their gaps are, and whether they are closing them. A readiness measure against the real pass mark, backed by activity and a per-topic view, turns “they are studying” into “they are at 72 percent and rising, with two weak topics left.” That is a far stronger thing to have in the file, and a far better basis for a supervision conversation, than hours logged.

PassPath is an independent preparation tool, not affiliated with the FSCA or Moonstone, and it does not administer the exam or guarantee a result. What it does is measure readiness against the real pass mark and show where the gaps are, which is exactly the kind of ongoing evidence a competence file benefits from.

What does an auditor or the FSCA look for?

An external reviewer is rarely trying to catch you out on a single missing certificate. They are testing whether you have a system: a register that is owned, current and backed by evidence, and a supervision process that acts on what the register shows. The questions tend to be practical. Can you produce, for a named representative, their DOFA, their deadline, their current exam status, and the qualifications behind their authorised categories? Can you show that you reviewed their progress recently, and what you did when someone fell behind?

A register that answers those questions in minutes signals a firm in control of its competence obligations. One that requires a scramble signals the opposite, even if every individual turns out, in the end, to be compliant. The difference is not the underlying facts; it is whether you kept them current and connected. This is why the review rhythm matters as much as the fields themselves: a snapshot proves a moment, but a dated review trail proves a process.

It also pays to be honest about gaps in the register itself. A note that reads “supervision arrangement under review, action due by month-end” is far better than a silent blank, because it shows you know where you stand. The goal is not a register that looks perfect; it is one that is accurate, current and defensible.

How do you make this less of an admin burden?

The reason competence registers go stale is that maintaining one by hand is genuinely tedious: chasing screenshots, forwarding results, and reconciling a spreadsheet that three people edit. The way out is to collapse three jobs into one system: prepare the representative, show their readiness, and export the evidence.

That is the model behind PassPath Teams. A manager sees each rep’s readiness score and band, coverage, activity and deadline countdown, with at-risk and stalled flags, and can export a CSV that slots straight into the competence file. You never see an individual’s private answers, only the readiness reporting you need. See how the dashboard and export work on the For teams page, and the pricing for per-seat costs.

None of this replaces your judgement or the official requirements. It just means the register reflects reality continuously, instead of being rebuilt from memory the week before an audit.