Proposals for a QAS Practising Certificates Scheme

I invite you to participate in this consultation about the proposed introduction of a Practising Certificates (PC) Scheme for Quality Assurance Scheme (QAS) accredited organisations.

During the recent review of the PC Scheme, the Regulatory Board committed to revisiting the possible integration of the PC Scheme with the QAS. Following a refresh of the QAS in April 2022 and the launch of the new PC Scheme in December 2022, the Board has been considering whether there is an option for a more streamlined approach to the Practising Certificates process for QAS accredited organisations.

This consultation sets out proposals for an optional QAS PC Scheme, offering a more streamlined approach for those who opt-in to the Scheme. Recognising the robust processes organisations must go through to meet the standard for QAS accreditation, it is proposed that those organisations who opt-in to the QAS PC Scheme provide a declaration covering each of their PC holders as part of their QAS Annual Return. This will replace the requirement for those PC holders working within those organisations to complete an Annual Renewal PC application. The Scheme also proposes that a full renewal for QAS PCs would be required after 6 years (rather than the 3 for those in the IFoA Practising Certificates Scheme). It is important to note that the proposals only relate to the renewal of PCs and all initial applications for PCs will continue to be considered and issued by the IFoA (in exactly the same way as for the IFoA PC Scheme, using the same forms and processes).

The aim of this potential approach is to enhance the QAS’ reputation in the profession and demonstrate the IFoA’s integrity as a modern, progressive regulatory body, while protecting the public interest by maintaining the Actuarial Profession Standards and the requirements of the Practising Certificates Scheme.

This webpage sets out the Board’s proposals in relation to a QAS Practising Certificates Scheme, and the rationale for the proposed changes.

The Board welcomes comments on the proposals from individual Members, employers of actuaries, other regulators and anyone else with an interest in the standards which the IFoA sets for its Members.

This consultation asks a number of questions, and we would encourage you to provide comments to support your answers.

We thank you for taking the time to consider these proposals and look forward to receiving your comments.

Neil Buckley
Chair of Regulatory Board


The QAS is a voluntary, outcomes-based accreditation scheme for organisations that employ actuaries.

Through the QAS process, the IFoA has assessed QAS accredited organisations as meeting a range of outcomes relating to the working environment for, and professional development of, its actuaries.

The QAS covers 69% of Practising Certificate (PC) holders (UK only), including 94% of UK Scheme Actuary PC holders and 18% of non-Scheme Actuary PC holders (UK only).

As part of the recent PC review, it was proposed that it may be beneficial to consider whether there may be potential efficiencies achieved through integration of the PC Scheme and the QAS.

When consulting on changes to the PC Scheme, respondents were asked about the extent to which they agreed that further consideration should be given to the possible integration of the QAS and the PC Scheme.

There were a range of responses received, with 58% agreeing or strongly agreeing that further consideration should be given to possible integration, and 42% disagreeing or strongly disagreeing with the proposal.

Following the consultation, it was agreed that further research and consultation with relevant stakeholders would be carried out once the wider changes to the PC Scheme had been implemented.

Consideration has now been given as to how possible interaction could potentially work with the new approach.


Integration of QAS and PC Scheme (optional scheme)

It is proposed that an optional PC Scheme for QAS accredited organisations is introduced – the ‘QAS PC Scheme’.

The proposed streamlined approach recognises that QAS accredited organisations have been assessed as having robust policies, procedures and practices in place to support their actuaries’ work. The existence of the QAS accreditation demonstrates commitment to each of the QAS outcomes, including in relation to professionalism, speaking up and conflicts of interest.

The QAS PC Scheme will enable Members at QAS accredited organisations who opt-in to the Scheme to benefit from a dynamic, Member focused Scheme, which reduces the administrative requirements of holding a PC by half.

The proposals for a QAS PC Scheme are set out below:

  • The QAS Annual Return will be amended to include a section for the QAS PC Scheme whereby participating organisations must declare that there have been no material changes to their PC holders in terms of fitness and properness, their roles and their meeting of the relevant competencies set out in the IFoA PC Scheme. The organisation will also be asked to explain the process followed to enable it to make such a declaration. This would replace the requirement of completing an Annual Renewal PC Application for those individual PC holders, but the IFoA would still issue an annual PC based on the information confirmed by the employer.
  • All individuals who hold PCs under the QAS PC Scheme will complete a Full Renewal PC Application after 6 years (unless there is a material change in circumstances, as set out above), rather than the current 3-year full renewal process.
  • The IFoA will carry out a random sampling of 5% of those who hold QAS PCs, to ensure their continued competence. This will take place via an interview carried out by either a member of the Executive or of the PCC.
  • Any QAS PC Holder who moves from a firm which is participating in the QAS PC Scheme to one who is not, will return to the IFoA PC Scheme at their next annual renewal date (i.e. complete an individual Annual Renewal form) and will be required to complete a full renewal application 3 years from their last full renewal.
  • Any PC Holder who joins a QAS PC Scheme firm will be included in the next QAS Annual Return and will complete their next full renewal at the 6-year anniversary point of their initial PC, or full renewal, being granted.

It is important to note that the proposals only relate to the renewal of PCs and all initial applications for PCs will continue to be considered and issued by the IFoA (in exactly the same way as for the IFoA PC Scheme, using the same forms and processes).

In addition, QAS accredited firms who opt into the proposed scheme will not issue their own PCs. The IFoA will continue to issue all PCs.

Under this proposed scheme, the IFoA will maintain full oversight of the process and of which individuals will be granted a PC.

Guidance and training

Guidance and training on the assessment of competencies will be provided by the IFoA to ensure consistency. This will include a training session for those QAS accredited firms which opt-in to the QAS PC Scheme as well as guidance documentation and access to the IFoA Executive team who can provide 1-1 support for organisations.

Conflicts of interest

It is noted that one of the main concerns in relation to introducing such a scheme is around real or perceived conflicts of interest.

The IFoA has considered this and suggests that the following mitigating factors will minimise any risks in relation to potential conflicts:

  • The IFoA considering and issuing ALL initial applications
  • The setting of clear guidelines, in line with the IFoA’s Competency Frameworks
  • The ability for individuals to opt in to the IFoA Scheme if there is a conflict (for example should a SQAR be required to complete a renewal for their manager). This would also be an option for any individual working for a QAS firm that would prefer an independent assessment of their application
  • Random spot checks by the IFoA to ensure continued competence (see above)
  • Assessment of policies and procedures by ICAEW, or another agent, prior to participation in the scheme being permitted
  • The QAS Annual Return form requiring not only the certification that there have been no material changes in circumstances for any PC holder, but also requiring detail of how this has been established by the person completing the form
  • The professional responsibilities on individual members and on members of the QAS, and the potential consequences in terms of discipline or removal from the QAS of failing to meet these responsibilities

Regulatory Impact Assessment

The QAS is an optional scheme for the employers of actuaries. This impact assessment assumes that an organisation which joins the optional QAS PC Scheme has already been accredited under the QAS.

The proposals will affect Members who work for QAS organisations and who choose to opt-in to the QAS PC Scheme.

The proposed scheme is offered in recognition of the various steps that QAS accredited organisations must take to be deemed eligible for accreditation, the way in which continued meeting of QAS standards is carried out, and the crossover between the QAS Outcomes and the PC Competencies.

Due to the crossover of the QAS outcomes and the PC Competency Frameworks, QAS accredited organisations are considered to be well placed to assess the competencies of their employees.

It may also offer those organisations the opportunity to assess competence in other ways than through a written assessment, therefore promoting more inclusivity.

The IFoA will provide guidance and training to ensure consistency of approach in applying the Competency Frameworks

The IFoA’s PC team will review the section of the QAS Annual Return relating to PCs (as they do all PC returns) to maintain consistency in how the standards are applied. It is also anticipated that there would be no increase in overall workload for either the QAS or PC Teams.

In terms of impact on the accredited organisation there are two potentially significant impacts:

  • Senior Quality Assurance Representatives (SQARs) at accredited organisations will need to be senior enough within the organisation to certify that each individual PC holder continues to meet the required standards and that there have been no material changes in circumstance which affect eligibility to do so.

There will be an imbalance in power, should the SQAR be required to certify this for (for example) their line manager.

This is mitigated by the ability of any individual to participate in the IFoA’s PC Scheme, and this would be the expectation in this situation.

  • A process will need to be established to enable the SQAR to be satisfied that the individual PC holders at their organisation continue to meet the requirements to hold a PC.

Given that each accredited organisation has policies and procedures in place relating to the QAS Outcomes, it is not expected that this will be an onerous task and QAS accredited organisations would be well positioned to do this.

Any risk associated with this is mitigated by the requirement that an external assessment will take place to verify the policies and procedures. It is intended that this is carried out by ICAEW, who carry out the other QAS external verification work on behalf of the IFoA.

Any organisation which is not QAS accredited will be required to apply for and be granted QAS accreditation prior to being eligible to participate in the QAS PC Scheme.

How to respond to this consultation

You can respond on behalf of an organisation or provide a personal response. To provide your response please (one of the following):

The deadline for responses is 30 August 2024.

Once the consultation has closed, the IFoA will reflect upon the feedback and publish more specific details of any changes. There will also be a period allowed before the changes come into effect so that those affected can take steps to ensure they are able to comply with the new requirements.

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