How Many Files Do You Need to Achieve Competent Adviser Status (CAS)?

It’s probably the most common question new mortgage advisers ask…

“How many files do I need before I can get Competent Adviser Status?”

Some people will tell you 5, others will say 10. We’ve even heard firms insist on 20 or more.

The truth?

The FCA doesn’t specify a minimum number of files.

There is no rule in the FCA Handbook that says an adviser automatically becomes competent after completing a certain number of mortgage cases.

Instead, firms are responsible for deciding when an adviser has demonstrated the knowledge, skills and competence to advise customers without supervision.

In this guide we’ll explain:

Does the FCA specify a number of files?
What should firms actually be assessing?
Why file quality matters more than file quantity.
How to evidence Competent Adviser Status.
How independent file assessments can support CAS decisions.

Does the FCA Specify a Minimum Number of Files?

No.

The FCA’s Training and Competence rules require firms to ensure advisers are appropriately supervised until they have demonstrated competence.

What the FCA doesn’t do is specify:

A minimum number of mortgage applications.
A minimum period of supervision.
A standard CAS programme.
A pass mark for file reviews.

Instead, firms must decide whether an adviser has demonstrated competence based on the evidence available. Every adviser develops at a different pace.

Why There Isn’t a Magic Number

Imagine two advisers.

Adviser A completes 10 mortgage files but repeatedly makes the same documentation errors, struggles with affordability assessments and needs constant support.

Adviser B completes 5 files, demonstrates excellent technical knowledge, produces consistently suitable advice and quickly incorporates feedback into future cases.

Which adviser is genuinely ready? Most firms would agree it’s Adviser B. Competence isn’t measured by volume, it’s measured by consistency.

What Should Firms Be Looking For?

Rather than counting files, firms should assess whether advisers consistently demonstrate good practice.

Areas typically reviewed include:

Fact Finding

Has sufficient information been gathered?

Does the fact find support the recommendation?

Suitability

Is the recommendation appropriate for the customer’s objectives and circumstances?

Is the rationale clearly documented?

Research

Has appropriate research been completed?

Can the adviser justify why the recommended product was selected?

Affordability

Has the adviser assessed affordability correctly?

Are assumptions documented?

Has the lender criteria been considered?

Documentation

Are file notes complete?

Is supporting evidence retained?

Would another adviser understand the advice process from the records?

Consumer Duty

Does the advice demonstrate good customer outcomes?

Has vulnerability been considered?

Has information been communicated clearly?

Quality Beats Quantity Every Time

Completing more files only adds value if the quality remains consistently high. Many firms therefore review files throughout the CAS process rather than waiting until an adviser reaches an arbitrary number. This allows learning points to be identified early and gives advisers the opportunity to improve before final sign-off.

What Evidence Supports CAS?

A robust CAS decision should normally include evidence such as:

Qualification certificates.
Training records.
CPD records.
Supervision meetings.
Knowledge assessments.
Observed appointments.
File review reports.
Development plans.
Final competency assessment.

Taken together, these provide a much stronger basis for awarding CAS than simply stating an adviser has completed “20 files”.

Common Mistakes We See

Some firms still rely too heavily on numbers.

Common mistakes include:

❌ Signing advisers off purely because they’ve reached a target number of files.

❌ Failing to record learning points.

❌ Reviewing files without giving structured feedback.

❌ Inconsistent grading between reviewers.

❌ Limited evidence supporting the final CAS decision.

So… How Many Files Is Enough?

There isn’t a universal answer. Some advisers may demonstrate competence after relatively few supervised cases. Others may require significantly more development. The important question isn’t:

“How many files have they completed?”

It’s:

“Can we evidence that they consistently deliver suitable advice without supervision?”

If the answer is yes—and you have the evidence to support it—you are in a much stronger position than simply relying on a number.

Final Checklist

Before awarding Competent Adviser Status, ask yourself:

✔ Have the adviser consistently demonstrated suitable advice?

✔ Have file reviews shown continuous improvement?

✔ Have you assessed technical knowledge?

✔Has the adviser acted upon constructive feedback?

✔ Can your decision be evidenced?

✔ Would you confidently justify your decision to the FCA?

If you can answer “yes” to each question, you’re focusing on what really matters.

Final Thoughts

Competent Adviser Status isn’t achieved by reaching a magic number of mortgage files. It’s achieved by demonstrating competence.

A well-structured CAS process should assess advice quality, technical knowledge, regulatory understanding and the ability to deliver consistently good customer outcomes—not simply count completed applications.

At H3 Consultancy, we help firms make confident CAS decisions through independent pre-submission file reviews. We assess mortgage files before they are submitted, grade each case against defined quality standards, provide detailed feedback for advisers and identify recurring themes that may require further development.

Our structured grading process gives firms objective evidence to support Competent Adviser Status decisions and helps ensure advisers are signed off because they are genuinely ready—not simply because they’ve completed enough files.arding Competent Adviser Status, our file review and competency assessment service provides objective evidence to support your decision-making.