What changed this quarter, and what it means for training
Three regulatory changes that affect mandatory training content, and the one that does not despite the headlines.

Compliance teams are told about changes far more often than they are told which changes require them to do anything. This quarter produced three that do.
Recordkeeping
The retention expectation for training evidence has moved from reasonable to a stated period. If your evidence lives in an LMS that overwrites completion records when a course is updated, that is now a finding waiting to happen.
Assessment integrity
The second change is quieter and more awkward: passing a module is no longer sufficient evidence of competence where the role is customer-facing. Expect to be asked how your assessment distinguishes between somebody who understood the material and somebody who clicked through it.
And one that changed nothing
The consultation everyone forwarded in March closed without altering the training obligation at all. It is worth reading anyway — the direction of travel is unmistakable.

Why annual compliance training does not work
Completion rates measure attendance. Here is what we measure instead, and what changed when we started.
Published Sep 12, 2026

The five questions auditors ask about training records
Taken from a year of audit support. None of them are about completion percentages.
Published Sep 12, 2026