Answers for firms on key CPD questions

Under the revised CPD Regulations (effective 1 November 2023), the following have a responsibility to comply with the requirements for firms:

• ICAEW member firms;
• firms that have been granted a dispensation to use the description “chartered accountants”; and
• firms regulated by ICAEW for audit, local audit, investment business, probate work or as a licensed practice.

This is not restricted to UK firms and includes firms located elsewhere falling within these definitions.

Under the CPD Regulations firms have a responsibility to ensure that affected employees (as detailed in "which staff are in scope") are compliant with these regulations.

This means that firms will need:

• a process to review and monitor employee CPD records;
• to consider whether individuals have correctly assessed which CPD category they sit in;
• to check individuals have carried out the minimum required hours, including verifiable hours and mandatory ethics training; and
• to retain records, including evidence of verifiable CPD, for three years after the completion of a CPD year. 

The CPD Regulations require individuals to correctly assess which CPD category they sit in. This must consider all work they carry out (both inside and outside their employment).

Based on this they will need to reflect on their development needs and carry out the required minimum number of hours, including the mandatory ethics requirement.

They will need to be able to provide records to support their CPD.

The requirements are not cumulative. Rather, the member must meet the CPD requirements for the role that has the highest number of CPD hours.

For example, if a member has one role that puts them in practice category 2, and another that puts them in not-in-practice category 1, they must undertake the CPD requirements of not-in-practice category 1 of 40 minimum hours.

We expect a member in that situation to apply their judgment to think about what their learning needs are across those multiple roles and act accordingly.

Firms are not responsible for the CPD that a staff member must complete due to a role outside of their employment with them.

The rules apply to ICAEW members carrying out accountancy or finance work, or reserved or non-reserved legal services; and anyone who is regulated by ICAEW. This includes:

• responsible individuals (RIs) for audit;
• key audit partners (KAPs) for local audit;
• insolvency practitioners;
• those who are licensed for probate; and
• licensed practitioners under the licensed practice scheme.

Many ICAEW member firms have affiliates, but these have no special status for CPD. If such employees are also regulated individuals, then they will be in scope.

The CPD Regulations also do not apply to ACA students.

Individuals who are not ICAEW members but hold the Business & Finance Professional qualification do not have to complete a minimum number of hours of CPD. However, they are subject to the existing RAID approach to CPD and are required to complete at least one hour of ethics CPD per year.

There is no difference between the way the regulations are applied to full-time or part-time workers. The minimum hours requirements apply regardless of whether a member or regulated person works part-time or full-time.

The decision was made to not prorate CPD hours as those working part-time need to be as technically up to date and as competent as their full-time colleagues. It doesn’t matter if someone is working two days a week or working five, they need to keep abreast of technical issues and changing requirements.

There is, however, a de minimis amount of earnings below which members do not have to complete a minimum number of CPD hours.

If an individual's total gross income from accountancy and finance services is less than £1,000 per annum, then they can also choose to reflect on development needs and undertake any necessary training.

Employees only working part of a CPD year are required to carry out a pro-rata amount of the minimum hours required for their role.

This could include employees taking a career break, on parental leave or long-term sick leave. For example, an individual on sick leave for 10 months of the year, would be required to complete one-sixth of the hours for that CPD year.

However, you have a responsibility to ensure your staff are competent for the work they carry out. You may decide that additional training is needed, for example, if there have been significant changes in regulations or standards during their absence.

While we wouldn’t hold the firm accountable for a whole year’s CPD if an employee wasn’t employed for the whole of that year, the firm does have a responsibility to ensure that staff are competent.

Firms should make sure that new staff members are aware of their responsibility to comply with CPD requirements and complete a pro-rata amount of minimum hours for the year they join. 

No. Once qualified as members these individuals will be required to meet the CPD Regulations.

If students qualify part way through a CPD year, then they must complete a pro rata amount of CPD. For example, if they qualify six months into the CPD year, they must complete half of the required annual minimum hours.

For subcontractors in scope of the CPD Regulations, you only have responsibility for the work they carry out for you. Anything they do outside of their work for your firm is their responsibility, including if this puts them in a different CPD category. They will need to maintain their own records to support this.

Reciprocal members are those who have either become a member of ICAEW, or joined another professional body, via a reciprocal membership agreement which ICAEW has with certain bodies in other countries (see the full list of reciprocal membership bodies).

Under those agreements there is an option for the individual to choose to comply with their home body’s CPD regime, rather than ICAEW’s, unless they are a responsible individual (RI) or key audit partner (KAP). If they are RIs or KAPs, then in those circumstances they must comply with ICAEW’s CPD Regulations.

Other than those who are RIs or KAPs, the firm's responsibility may be limited to ensuring the reciprocal member is exempt from complying with the CPD Regulations (through satisfying the CPD requirements and obligations relating to their other professional body).  

The CPD Regulations require firms to maintain records of how their staff are meeting their CPD requirements.

We’re not expecting records to be routinely submitted to us. Firms just need to have them available if we ask.

The records should contain details of the CPD activity, including number of hours completed. Where the CPD activity is considered to be verifiable, the records also need to contain sufficient evidence to support this.

ICAEW’s guidance on verifiable CPD includes examples of the type of evidence we expect to see.

You will need to retain this evidence as part of the overall CPD record for at least three years after a CPD year ends.

There is no prescribed format, you can decide how to record CPD. If your firm uses a learning management system you will already be recording CPD activity within the system. You may need to enhance this to include evidence of verifiable CPD.

If your firm doesn’t use a learning management system, you can use whatever method you prefer. For smaller firms, a simple and cost-effective method could be to use Excel-based records.

Individual staff can record their CPD in different ways, however, making the record consistent across the firm would make central monitoring easier and more efficient.

Firms can determine the best way for them to maintain CPD records of its ICAEW members, including using a learning management system, if they have one in place.

Although the detailed records and evidence to support verifiable CPD do not have to be retained centrally, firms do need to have monitoring processes in place to assess compliance with the regulations.

We would therefore expect them to have oversight of the CPD being carried out. If a firm delegates responsibility for CPD record keeping to its staff, it should ensure that it has access to these records, at least annually, to carry out this monitoring. All records need to be available to QAD if they ask for them during a monitoring visit.

For anyone using the ICAEW online CPD record, a CSV file can be downloaded that can be shared with the firm.

Firms should be reminding staff to share their learning records periodically through whatever process the firm has put in place to do so.

We’re not providing a system for firms to monitor CPD undertaken by their staff. We have created an online CPD record for members to track their own CPD.

Though firms will not have access to individuals' online ICAEW CPD record, members will be able to download a CSV file from that record and provide it to their firm to support monitoring.

You should ensure evidence of relevant and verifiable hours is retained for at least three years after a CPD year ends.

No, the ICAEW CPD year is from 1 November to 31 October, but we understand that firms may have different CPD years, for example, aligned to their financial year end. We don’t expect you to change this and we will consider the firm’s CPD year in our monitoring.

No. The only exception to this was anyone completing the ICAEW ethics CPD course prior to 1 November 2023. This learning will count towards the 2023/24 CPD year.

For a CPD activity to be classed as verifiable, independent evidence must be provided that proves it was carried out.

See further guidance and examples of what could constitute as evidence for CPD activities.

No. The only CPD that needs sign off is on-the-job learning or internal training for which there isn't another kind of evidence available.

You need a system for capturing what staff are doing in terms of CPD, but that's not the same as “signing it off”.

Technical reading is included in our guidance on 'what is verifiable CPD', however, it’s only verifiable if the reading can be evidenced. For example, if you were carrying out technical reading for a specific reason, maybe for a client, you may be able to demonstrate it's verifiable by producing the output as evidence.

If your technical reading is completed on icaew.com, we have developed the AddCPD tool that enables members to verify reading of articles and PDFs when logged in, and then add it to their online CPD record.

• Find out more about the new digital tools to support members with their CPD requirements.

Don't forget that not all of your CPD needs to be verifiable. While technical reading may not be verifiable, it will still count towards your overall number of CPD hours.

We've published guidance on 'what is verifiable CPD', which includes examples of where we think there will be independent evidence of that CPD being completed.

In the case of webinars, a certificate of completion or a registration email would count as evidence of verifiable CPD.

ICAEW members can also use AddCPD to verify watching videos and webinar recordings hosted on icaew.com webpages.

Many training providers are also working to ensure that their courses and training can be verified.

Yes. Lecturing is included in our list of examples of verifiable CPD. You could provide lecture materials or a record of the event as evidence.

Yes, internal training can count towards verifiable CPD as long as firms can provide evidence to support this activity. This evidence can be demonstrated in several ways, such as attendance records or a formal certificate of attendance from the internal system or training coordinator.

We also expect the CPD activity to be supported with details about how this is relevant to individuals’ roles and how it meets their specific learning outcomes. This may include providing details of the training content.

Firms can continue to use their own ethics training, but we ask that you compare the learning outcomes of your training to the ICAEW Ethics CPD Course to make sure that your firm’s training satisfies specified learning outcomes aligned to the ICAEW Code of Ethics.

Your training also needs to be a minimum of one hour each year and verifiable.

Note that we encourage most members to use our Ethics CPD Course, as it’s freely accessible and can be added to firms’ learning management systems.

• Find out more.

Yes, the course can be incorporated into your existing learning management system. Please contact us if you require this and we will take you through the process.

No. As firms have a responsibility to ensure staff are complying with the CPD Regulations, we suggest you ask members of your staff who complete the ICAEW Ethics CPD Course to separately record this within their CPD records.

Individuals also need to retain evidence to demonstrate they have done this. We suggest you check all staff have completed this as part of your CPD record checks.

There will be two different ways in which ICAEW will monitor CPD.

The first is the way in which we already monitor CPD compliance, in that we will select a sample of members and ask them to submit their CPD records.

If we identify non-compliance issues with CPD records from sampling individual members, we will speak to the individual. We will then ask for a commitment from that person to remediate the CPD records – ie, carry out the relevant amount of CPD – and we will follow that up. We also require the individual to let their firm know that they've been selected and that there was a problem within their CPD record.

The second will be firm monitoring. In many cases this monitoring will be carried out as a standalone CPD visit and will not be linked to any other regulatory or assurance visit that a firm may be subject to.

These visits will aim to gain an understanding of the firm’s CPD system and training regimes, as well as how training is rolled out and how monitoring is completed. We would then sample test some of the firm’s employee CPD records.

If we carry out a firm CPD visit and identify an issue, we'd speak to the firm and ask for a commitment of how they would resolve the point. If it's on an individual CPD record, for example, we'd want them to give us a confirmation that they're comfortable this isn't applying to anyone else. We will follow up the following year to make sure those records have been remediated.

If we identify significant issues or repeat issues, we will report them to the Practice Assurance Committee and ultimately there is a route to the Conduct Department (formerly the Professional Conduct Department), however, that will only be for serious instances of non-compliance.

We won’t be able to start monitoring visits until after the new CPD requirements have been in place for a year (ie, November 2024), as we need a full year of CPD records. We will then start doing monitoring visits. The number of visits will start at a low level and increase over time.