A high completion rate doesn't mean compliance training is working
Completion rates show who finished a course, not who will make the right call under pressure.
Compliance training typically means mandatory modules, annual refreshers and high completion records to be shared with boards and audit committees. All of which presents as an organisation protected from risk.
Yet organisations still face cases of wrongdoing or misconduct. High completion only shows that people clicked through the content. It doesn't show whether people know how and where it applies in their everyday work, or what to do in the moment a potential risk arises.
"People generally know the essential rules," says Owen Rose, a director at Acteon, a consultancy specialising in communication, learning and behaviour change. "What they find harder is applying that rule in the moment, especially when they're busy and under pressure. A completion rate doesn’t tell you whether compliance training has any impact on what they do in their everyday work."
AI adoption is a current example. In a 2025 global study of more than 48,000 people, led by the University of Melbourne with KPMG, 39% of UK employees said they had used AI at work in ways that contravene their organisation’s policies and guidelines.
When more training is the wrong answer
One large hospitality employer's experience shows how simply providing more training can miss the point. After its audit committee noticed a rise in conduct-related issues, the organisation approached Acteon in search of more training.
Employees were already completing long e-learning modules annually on the code of conduct with little reinforcement. Frontline staff were completing content on risk topics that had no relevance to their roles. And when asked, people were unable to recall key messages. Managers described the training as a tick-box exercise.
Ultimately conduct was shaped by local culture and managers, not the Code.
Instead of prescribing more training, Acteon looked at how to match training to the risks each role carried, base it on real situations, equip managers to hold conduct conversations, and replace the annual module with short learning moments through the year.
Training time now reflects the risks each role carries not only reducing the cost per head but improving responsible decision making in everyday work.
Completion matters. But it isn't evidence of workplace behaviour
Regulators and auditors expect records of who has been trained. The problem comes when completion is treated as the end point.
It can be harder to measure behaviour. But there are some simple things you can build into your approach that will really help.
Building better evidence
For L&D teams, a few practices make it more realistic to show that compliance training is working:
- Start with the action. Identify the situations where people are most likely to get it wrong, and describe exactly what a good response looks like. There will be some general ones and some that are more relevant to specific roles.
- Assess application. Use practice scenarios without an obvious right answer to reveal whether people can use a policy in the moment. Track results over time and you'll see where support is needed.
- Track a small set of workplace signals. Agree what matters. Maybe you want more people to speak up, more declarations or more questions to the compliance team. By tracking the baseline before implementing new solutions you can get a better understanding of what's working and what still needs addressing.
- Speak to your managers. Managers are usually the first people employees ask when they're unsure. Understand what they're being asked, and how confident they feel answering.
So rather than asking who completed the training, a better question to ask is what you would need to see to know people are making better decisions.
To find out more, check out further guidance from Acteon on designing code of conduct training around everyday decisions.