Under the new version of the code, expected to come into force next year, advisers must do 30 hours of structured continuing professional development over two years.

But they must be able to show how that training fits in with their business development and advice practice. What counts as structured CPD for one adviser could potentially be unstructured for another.

It cannot be training designed solely for the purpose of promoting a particular product.

Consultant David Whyte said that would cause confusion. “The 30 hours have to be relevant to your practice, and trotting along to a Sovereign sales seminar - or similar - will no longer qualify for CPD points. This makes life difficult for advisers who operate in specialist areas.  Who offers impartial presentations and seminars these days?”

He said most invitations to educational events carried the expectation of support.

Previously, CPD had been able to be called structured by virtue of being offered by a professional body. Now, those bodies will have to step back a bit and leave advisers to take responsibility for their own training.

IFA chief executive Penny Mudford said the biggest change for her organisation would be that advisers would need to manage their own programmes. “IFA will then play a role in assisting advisers to match their identified training needs to the learning outcomes and objectives in CPD events that are available to them.”

She said the IFA would continue to provide CPD because it was a core business for professional bodies and especially important for the industry in its current state of development.

“We support the outcomes-based approach the Code Committee is taking. However, if that is adopted as the sole criteria, we have identified a significant risk for the Code Committee in that the proposed re-definition of 'structured CPD' will result in greater inconsistencies in the learning programmes of AFAs. A stronger system would be to support the individual learning programmes with independent moderation and quality assurance which is currently provided by someone other than the adviser.”

Clayton Coplestone, whose firm, Heathcote Investment Partners, runs the Meet the Manager events for advisers, said his offering already had to meet a lot of criteria.

“We currently have this appraised by the IFA. Whilst the vetting process is onerous, we have figured that its best to certify the MTM via a credible industry body, as opposed to seeking ‘easier options’.”