Under the transitional arrangements in the Act, there is a "Competency safe harbour" built into the transitional period at the start of the new regime.
If you’re an RFA immediately before 15 March 2021, you have a transitional licence or you are engaged by a licensed financial advice provider to give advice on their behalf, and you don’t already meet the competence knowledge and skill requirements of the new Code, you can make use of the two-year “Competency safe harbour”, while you work towards meeting those standards. This competency safe harbour applies to you, personally: it allows you to continue, for the first two years of the regime, to give the financial advice that you were legally permitted to provide as an RFA for the first two years of the regime, even if you move to work for a different financial advice provider.
If you’re an AFA immediately before 15 March 2021, the new Code provides ways in which you may use your AFA authorisation to demonstrate your competence, knowledge, and skill (as set out in part 2 of the Code). We encourage you to check your authorisation against the new Code to make sure you meet the particular competency requirements for the advice you intend to give.
After two years, the competency safe harbour expires and you will need to meet the standards of competence, knowledge and skill outlined in Part 2 of the new Code.