How to fix our senseless compliance training

All big organisations have a Learning Management System.

It’s used to track and record the training that the employees do. In practice, it tends to be used to administer compliance training, though it can be much broader than that.

And this is a good thing. Despite the scorn that LMS’s attract, we should be tracking and recording the training that our employees do – especially compliance training.

Looking up at skyscrapers

But here’s the rub…

Let’s say I work at Bank A. I do all my compliance training within the first 3 months of starting at the company, and I keep those certifications up to date every 2 years. That’s normal.

Then I get a job at Bank B. But because my training records are locked up in Bank A’s LMS, I have to do my compliance training all over again.

This does not make any sense, because the laws governing privacy, anti money laundering, OH&S, and all the other topics, are the same for both banks! If I’m compliant at Bank A, odds are I’m compliant at Bank B as well.

I see re-doing my compliance training as a problem, not just because it’s an inconvenience for me personally, but also because the financial services sector alone employs half a million people in Australia. That’s a lot of people, a lot of movement, a lot of training hours, and a lot of wastage.

There has to be a better way, and as I explain in the video below, I propose the accreditation of compliance training with open badges as the solution.

Now some people misunderstand this idea, and they’ll say it’s not the role of the regulator to train a company’s employees. And I agree, but that’s not the idea.

The idea is that the regulator accredits the training that is delivered by the company to its employees, and authorises the issuing of the official badges for that training.

25 thoughts on “How to fix our senseless compliance training

  1. You make some excellent points Ryan that go beyond the financial services sector and effects almost every industry. In some situations employees do enormous amounts of ‘in house’ training, which while it may meet the needs of compliance regulations has not transferability, because every organisation wants (and probably should) put their own spin in it.

    One suggestion is to link in house training to nationally accredited training, but while i see the point in this and support it in lot of cases, there are significant issues, the least of which is that a lot of the training organisations do for their staff don’t fit well with accredited outcomes. On top of that you have at least in some cases additional costs associated with nationally accredited outcomes.

    Those of you who know me know that I am not an enormous fan of badges, however in the case that Ryan speaks to I can see the sense in some kind of ‘accredited’ identifier, be that a badge, or an authenticated certificate.

    The accredited training sector now what is know as the universal student identifier (USI) a number which people can use to access and produce a certified copy of all of the nationally accredited training they have undertaken, which while only having running for 18 months or so is making a significant difference to the issues of determining if someone holds or has done particular training.

  2. Thanks Paul.

    The in-house training issue is important because many organisations indeed put their own spin on it – and rightly so in a sense, as they have their own processes and systems etc. However I think this can be overcome by having accredited modules that are universally applicable, while the organisation’s peculiarities could be covered by a supplement during induction.

    I’d like to learn more about your observation of a lot of the training that organisations do for their staff not fitting well with accredited outcomes. This waves a big red flag for me. Why is this the case, and should we be concerned about it? In the context of mandatory compliance, the training must meet the demands of the regulations!

    The USI protocol sounds like a giant leap forward. The advantage of open badges (or indeed, some other digital device) is that the transaction can be automated between IT systems. Perhaps USIs and badges can be combined somehow?

  3. HI Ryan:

    I really like your approach here: focusing on an immediate practical issue, that may pave the way for further innovation down the road.

    Unlike LMSs, Open Badges focus on the recognition and accreditation of learning, rather than learning content or delivery (I’m being a little unfair here – learners can have profiles in LMSs, but work with me.).

    As a common standard for micro-credentials, Open Badges are technically portable. If they also point to commonly recognized skills (or compliance) standards, they become functionally portable.

    If these conditions are met, Open Badges become modular records of learning that can travel with the learner, rather than remain behind in the original learning silo. That saves time and money. This recognition of learning also values the learner – a big factor in employee retention.

  4. Hi Ryan,

    A really interesting article, and something that is challenge across many industries. Repetition of compliance training is a burden for those working in healthcare for example, who may work in one or two companies at the same time, or move frequently, and have to re-do the same compliance training.

    It’s something we’re addressing with our portable learner records in Qintil, an LMS we’ve just launched which makes the learner central, and all their learning and education portable and visible to employers they choose to share it with. Having learners ‘own’ their training improves engagement as well.

    I’d be keen to get your thoughts on it from a financial services perspective.


  5. Thanks Sam.

    Qintil sounds very interesting. If the individual chooses to share their learning records with their new employer, are they then reliant on the employer reciprocating (or can they push it through)? Also, must the new employer’s LMS be compatible with a specific standard?

    In any case, I agree these problems are important to solve not only in financial services but also in other industries such as healthcare. And I concur that having learners “own” their training improves engagement as well.

  6. Hi Ryan,

    The learner has a complete record of their learning and other educational experiences (workshops, conferences, reading etc) and doesn’t require the employer to reciprocate, it’s pushed through as part of the learners record. The new employer can then choose to accept that qualification towards their compliance, and store it into the LMS against a mandatory or other compliance requirement.

    Right now it’s unique to our LMS and the employer would need a Qintil account but we’re looking at how the record can be interoperable with other platforms.


  7. Brilliant. It’s such a simple idea but obviously too hard to do. You talk about saving time but what is the actual dollar figure for that? If you looked at average wage (say $25 hour – looking at times by the 5 hours (average time assuming reading and testing) then you are looking at a potential saving of $125 per person. Not much by multiply by the thousands of movements each year it becomes a substantial saving (that the financial service businesses desperately need). Another very radical and left of field concept would be to then have the compliance training actually be more than ticking a box and generate real learning and outcomes.

  8. Thanks Matt.

    When you do the maths, the dollar savings are significant for an individual organisation, huge across the sector, and impactful for the national economy.

    Indeed, improving the efficiency of compliance training is different from improving its quality, which I agree is also sorely needed.

  9. Ryan,

    The problem is that accredited outcomes are often more expansive than what the minimum compliance standard is. The minimum in terms of compliance is in a lot of cases a subset of a single unit of competency. The legislation sets out what the minimum requirements are, these requirements of course can be met in a number of ways and may only be a small part of an overall accredited outcome. Take WHS for example not everyone needs to do a Certificate IV in work health and safety or even an entire unit from the course in order to meet the basis legislative requirements. It is not a problem necessarily that they are not tightly linked but it does make for issues.

    Unfortunately being a government controlled data collection, which also collects a whole pile of personal information along with training data, linking it with anything like badges will never happen,

  10. I see, Paul, so linking in-house training to nationally accredited training (by which I think you are referring to the Australian Qualifications Framework) would be problematic. Thanks for explaining that.

  11. Hi Ryan,
    I like the concept but I reckon it would be an uphill sell. I drop in and out of finance and regulated industries quite often with my work. My experience is there’s a high level of risk aversion when it comes to compliance type stuff. I remember reading somewhere once the LMS acronym (disparagingly) stands for litigation management system.
    I have had conversations with senior exec and senior lawyers about mobility of fraud and WHS training that is consistent across this particular sector. It was shot down by everyone. The arguments were to the effect it’s not contextualised, they don’t have control of the content, their lawyers haven’t cleared it, etc. I’ve come to the conclusion they’re not thinking about the benefits to the employees or the organisation, they’re thinking about covering their backsides.

    It’s organisational stupidity, but maybe it’s fair enough. On several occasions in different organisations in the last 12 months I have seen senior execs and those in the C-suite fired when someone down the change of command has tried something that hasn’t work. What’s the best way to not get fired for trying something? Do nothing. This permeates through the culture. The organisational consequence of doing nothing is normally far worse from than doing something (but you don’t get fired).

    Since this struck me I invest my energies away from compliance training. This became a bit of rant, sorry. Again, your idea is a good one and your points are compelling. Good luck :)

  12. Thanks for your rant, Ben :)

    I am under no illusions… my proposal will never be implemented in this country – even if it saves millions of dollars in productivity for the national economy – because too many selfish forces are against it.

    Never mind the fact the naysayers’ arguments are rooted in the one-off event mentality of compliance training, and betray a disturbing lack of confidence in our regulatory authorities, it makes you wonder why we bother with compliance at all!

  13. Good idea in principle, certainly. Needless retraining is a waste on many fronts. If you have an industry where there is government regulation, it does make sense that the regulator should get involved to ensure the transferability of compliance training accreditation. I wonder how common this is, though? People still go through needless training because they haven’t got the normal qualification, certificate or licence.

    In these cases, what is necessary is more transparency, so that each organisation can clearly recognise which parts of their training are necessary, and which are redundant. And we can achieve that transparency by creating detailed frameworks for the skills or competencies that have been trained for and certified.

    There is still the question of cross-comparison. If people were to reuse frameworks, or parts of frameworks, rather than inventing their own each time, it would be much clearer. Even when the frameworks are different, there is a lot to be gained by cross-mapping parts of the framework — and this is easier, the smaller parts we are dealing with.

    The InLOC specification makes all of this possible in a well-thought-through way. InLOC — “Integrating Learning Outcomes and Competences” — is a specification for how to construct and communicate a framework electronically, and how to cross-map its parts in ways that a IT system can process effectively. It is a natural complement to Open Badges. See the spec at and two blog posts on the relationship from 2013 — — and

    Hope this may be of interest.

  14. Simple and seems like it might work. There is a logic behind it that is also behind open badges – and while there might be sectors in which implementation of open badges will be complicated – as it was shown in some of the comments – the general trend is there.

  15. Thanks Nikos. I think we tend to over complicate things at times. That’s not to say the inherent nature of our business is uncomplicated, but I believe there are opportunities to make improvements if we take the time to think about them systemically.

  16. @Ryan
    Yes, but there’s another problem here. Taking a few steps back, disentangling things which arrived at this level of complexity and this was called and generally treated as development. And there were few experts involved in this, who in case of trying to simplify things would react, how? Maybe defending the status quo. Cause “only an expert can deal with a problem”.

    I believe that’s a pretty revolutionary thought what you’re saying, my friend :)

  17. I see a problem here and that’s to do with the way that the Backpack works, at least last time I looked. Correct me if I’m wrong, but when a badge is issued by an LMS, it’s usually tied to an email address.

    When a company issues a badge to it’s staff via it’s LMS, it usually issues it to that staff members email address. They will have to set up a Mozilla backpack attached to that email address.

    The problem, last time I looked, was that the backpack did not accept more than one email address.

    When a person then moves to a different company, their corporate email address is taken away and *bosh*, they no longer have their badges in a usable backpack.

    As I say, this was the case last time I looked, maybe Mozilla has made improvements to the Backpack since then, as this made badges extemely unportable indeed

  18. This is indeed a problem Andy, and a known issue:

    I know that Credly allows for multiple email addresses to be attached to the one account, so I’m surprised that wasn’t factored into Mozilla’s backpack. Given that Mozilla has now stepped away from the OBI, we may be reliant on the open source community filling the gap or another sponsor stepping in.

    An alternative may be for the LMS to accommodate the learner’s personal backpack details, so that it issues the badge to the “right” email address.

  19. Just checking back in on this… any takeup on this issue in your sector, Ryan? I’m presenting use cases for business in a few upcoming workshops and it would be interesting to know if there was movement..
    And by the way, the single email address issue has been addressed in the new Open Badges spec. Other public backpacks such as Open Badge Passport and Badgr have already solved it. Backpack should follow(it’s now being hosted by DIgitalMe with Mozilla’s blessing.

  20. Zero interest, I’m afraid Don. My reaching out has either been ignored, or been met with a variation of “that’s not our job”.

    *Insert raised eyebrows here*

    Nonetheless, great news about the email address issue, and please let me know how your workshops go.

  21. Disappointing, but I think it’s just a matter of time, Ryan. New ideas take a while to percolate… who knows, maybe it will reappear as somebody else’s idea. It does occur to me that the people in charge of training budgets should be interested.

    Happy to report back about the BC Open Badges Forum and other efforts to get Open Badges onto regional skills radars.

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